Hazardous Waste Generator Handbook

Transcription

1 Hazardous Waste Generator Handbook May 1, 2011 Revised April 16, 2014 A Guide to Complying with Kansas Hazardous Waste Generator Regulations Kansas Department of Health and Environment Division of Environment Bureau of Waste Management 1000 SW Jackson, Suite 320 Topeka, KS (785)

2 DISCLAIMER: This handbook supersedes all previous editions of this publication. The information contained in this handbook is an overview of the hazardous waste management program in Kansas. The state and federal regulations should be consulted for more detailed information. 2

3 Hazardous Waste Generator Handbook Table of Contents I. Background 4 II. Purpose 4 III. Who Generates Hazardous Waste and Who Does Not? 5 IV. What is a Hazardous Waste? 5 Insert. Hazardous Waste Determinations and Documentation, HW-2010-G1 6 Insert. Characteristic and Listed Hazardous Wastes, HW-2011-G2 9 V. What Quantities of Hazardous Waste are Regulated? 13 VI. Generator Classifications 14 VII. Summary of Generator Requirements 14 VIII. IX. A. Conditionally Exempt Small Quantity Generator (CESQG) Requirements 14 B. Kansas Small Quantity Generator (KSQG) Requirements 17 C. Small Quantity Generator (SQG) Requirements 21 D. Large Quantity Generator (LQG) Requirements 25 Land Disposal Restrictions (40 CFR 268) and Hazardous Waste Manifesting (40 CFR 262) 29 Choosing a Hazardous Waste Management Facility and/or Hazardous Waste Transporter/Contractor 30 X. How to Avoid Compliance Problems and Minimize Liability 31 XI. Resources Available to Assist in Properly Managing Hazardous Waste 32 Attachment 1 - Toxicity Characteristic Constituents Regulatory Limits and Waste Codes 34 Attachment 2 - Hazardous Wastes From Non-Specific Sources (F-List) 36 Attachment 3 - Hazardous Wastes from Specific Sources (K-List) 40 Attachment 4 Discarded Acutely Toxic Commercial Chemical Products, Off-Specification Species, Container Residues and Spills Thereof (P-List) 47 Attachment 5 - Discarded Commercial Chemical Products, Off-Specification Species, Container Residues and Spills Thereof (U-List) 60 Attachment 6 - Training/Compliance Manual 85 3

4 I. Background The first effort to regulate hazardous waste management on a national level occurred in 1976 with the passage by Congress of the Resource Conservation and Recovery Act (RCRA). The primary goal of the Act was to encourage the conservation of natural resources through resource recovery. RCRA also provided the statutory basis for the federal hazardous waste regulations. The regulations that have evolved into the current regulatory program were first issued in May of A key section of the Act provided for states to operate the hazardous waste management program in lieu of the U.S. Environmental Protection Agency (EPA). The State of Kansas first passed legislation regarding hazardous waste management in The Kansas Department of Health and Environment (KDHE) obtained authorization to administer the hazardous waste management program from EPA in October of As a result, hazardous waste generators deal primarily with KDHE. Since 1977, Kansas hazardous waste laws have been amended, with significant updates being made in With a few exceptions, KDHE has adopted the federal regulations by reference. In areas where the Kansas regulations have different requirements than the federal program, the generator must comply with the state requirements. II. Purpose The proper management of hazardous wastes can be a complex and challenging task. This publication was prepared to be used as a guide to help you determine whether your facility is subject to state and federal hazardous waste management statutes and regulations. By reviewing waste generation and disposal practices, and using this guide, a person should be able to do the following: Determine whether your facility generates hazardous wastes; Determine how those wastes are regulated under the Kansas hazardous waste management program; Learn what you must do to comply with the Kansas hazardous waste management statutes and regulations; Learn what alternative hazardous waste management options are available to a hazardous waste generator; and Learn what resources are available to assist you in complying with the statutes and regulations. The hazardous waste statutes place the primary responsibility for ensuring that hazardous wastes are properly managed on the person/facility who generates those wastes. The generator must identify all hazardous wastes and be certain that they are transported and disposed in accordance with the law. While the generator can contract with hazardous waste contractors or consultants to perform these activities on his or her behalf, the ultimate responsibility for complying with the laws remains with the generator of the waste. For this reason, it is important for all generators of hazardous or potentially hazardous wastes to become familiar with the statutes and regulations that apply to them. The Kansas statutes and regulations generally mirror federal laws and regulations but differences do exist between the two programs. To comply with all the state regulations fully, you must use the Kansas hazardous waste regulations with the federal regulations referenced in the various state regulations. 4

5 Complying only with the federal regulations found in Title 40 of the Code of Federal Regulations (40 CFR) will not allow you to operate in full compliance with the Kansas regulations. III. Who Generates Hazardous Waste and Who Does Not? Any business can be a hazardous waste generator. A few examples of hazardous waste generators are businesses that use or handle large amounts of chemicals, manufacture items, perform maintenance activities, or conduct printing services. Wastes from households and most farm activities are exempt from the definition of hazardous waste. Therefore households and most farmers are not generators of hazardous waste. However, some wastes generated by households and farmers are very hazardous and should be managed appropriately. Most Kansas citizens have access to a household hazardous waste (HHW) collection facility. These HHW facilities are permitted by KDHE to collect wastes from households that may be hazardous and to keep HHW out of our landfills and out of our groundwater and surface water. KDHE encourages all citizens to utilize HHW facilities whenever possible. IV. What is a Hazardous Waste? Hazardous waste is a special category or subset of all wastes that businesses and industries generate. For a material to be a hazardous waste, the material must first be classified as a solid waste. Generally speaking, a material is a waste when it can no longer be used for its intended purpose and will be disposed, reclaimed, or recycled. Hazardous wastes are wastes known to be harmful or potentially harmful to human health or the environment. The process used to determine if a waste is hazardous is referred to as the hazardous waste determination. The following sections will detail the process of making an adequate hazardous waste determination, and also explain the different ways a waste can be hazardous (characteristic and listed). These sections are in the form of Technical Guidance Documents. For a complete list of Technical Guidance Documents, see the KDHE BWM website (address found on the cover of this document). 5

6 Kansas Department of Health and Environment Bureau of Waste Management 1000 SW Jackson, Suite 320, Topeka, Kansas Hazardous Waste Determinations and Documentation Technical Guidance Document HW-2011-G1 Businesses, government agencies, institutions, and other concerns generate many types of waste and are required to determine if any of their waste is hazardous. Only household waste is exempt from this requirement. This technical guidance document (TGD) explains the steps involved in making a waste determination and the associated documentation requirements. This guidance is not designed for every waste stream and should not be used without consulting the regulations. The Federal Regulations referred to in this document have been adopted by Kansas in KAR Making Waste Determinations Hazardous waste determinations can be complicated, and must be done for every waste stream generated at a facility. Generally, the only waste stream that is not required to have a documented waste determination is office trash. Breaking the waste determination into steps can make it easier to complete the process. Step 1 Make a list of all waste streams being generated at the facility. List what process generates each waste stream, and document how many pounds of each waste stream are generated each month (don t average over months). Step 2 Check to see if each waste meets the definition of solid waste as found in the Code of Federal Regulations, 40 CFR Waste is considered solid waste if it: Is a solid or a liquid (or in some cases a gas) that is discarded, abandoned, recycled, or considered inherently waste-like; and Is not otherwise exempt from the definition of solid waste under 40 CFR 261.4(a). One common way that materials become exempt from the definition of solid waste is when they are discharged to a sewer or drain that is regulated under the Clean Water Act, for example an NPDES discharge point, a prea Publicly Owned treatment system, or Treatment Works (POTW). Step 3 For each waste that meets the definition of solid waste, check to see if the waste meets the definition of hazardous waste as found in 40 CFR Use knowledge of how the waste was generated (process knowledge) and/or have the waste analyzed at a Kansas Department of Health and Environment (KDHE) certified laboratory using EPAapproved test methods. Some wastes may need to be evaluated using both process knowledge and analysis, while others can be evaluated using one or the other alone. Hazardous waste is divided into two broad categories: listed waste and characteristic waste. A hazardous waste can be both listed and characteristic. For more details on listed and characteristic hazardous wastes and determining waste codes, please refer to TGD HW-2011-G2, Characteristic and Listed Hazardous Wastes. Step 4 Prepare a document stating whether or not the waste is hazardous. If it is hazardous, list the applicable waste codes (D001, F003, U183, etc.). This is the very important final step in the hazardous waste determination process. Documenting Waste Determinations Maintain documentation of Steps 1 through 4. This documentation must be kept for 3 years from the last date the waste was shipped off- site. Page 1 of 2 4/29/2011

7 BWM TGD HW 2011-G1: Hazardous Waste Determinations and Documentation Adequate documentation will include a statement about whether or not the waste is hazardous as well as copies of all documents used in Steps 1 through 3. Documentation is required for all wastes, both non-hazardous and hazardous. Some examples of documentation that may be included are: Material Safety Data Sheets (MSDSs); Process flow diagrams; Analytical results from a KDHE-certified laboratory; and Chemical reaction diagrams. None of these documents is acceptable as an adequate waste determination by itself, as none of them will state conclusively whether or not the waste is hazardous or non-hazardous. Another document that is inadequate by itself is a Waste Profile from a contractor. These forms are often filled out by hazardous waste transporters and contractors through interviews with generators and frequently are not supported by any real investigation into the process generating the waste. In addition, they may be supported using analytical tests done in laboratories that are not certified by KDHE. Always ask the contractor to use a KDHEcertified laboratory for all analytical testing to ensure that a repeat analysis is not required. Also, if a Waste Profile is used as part of the hazardous waste determination, all supporting documentation, including those documents previously listed, must be attached. Adequately documenting waste determinations can be difficult. To assist with this process, KDHE has created the attached example document that may be used. This specific form is not required and may be modified to meet the specific needs of individual facilities. Summary Conducting an adequate determination for each waste stream and properly documenting that determination will help facilities stay in compliance and avoid costly mistakes. Adequate determinations are the foundation of any good hazardous waste management program and will help reduce management and disposal costs. Certified Laboratories A list of KDHE-certified laboratories can be found at: For additional information regarding proper management of solid or hazardous waste in Kansas, you may contact the Bureau of Waste Management at (785) or the address at the beginning of this document, or visit the Bureau=s website at Page 2 of 2 4/29/2011

8 Waste Determination Documentation Form Facility Name: Waste Name: Description of Process: Pounds of waste generated each month: Does this waste meet the definition of a solid waste? Yes No Is this waste exempt from the definition of solid waste or hazardous waste? Yes No Was laboratory analysis used to make this determination? Yes No If yes, record the name and KDHE certificate number for the laboratory: If yes, attach a copy of the analytical results to this sheet. Was knowledge of the process used to make this determination? Yes No If yes, list the name and date of each document (MSDS, process flow diagrams, etc.) reviewed and/or attach them to this sheet: Is this waste non-hazardous? Yes No Is this waste a listed hazardous waste? Yes No If yes, list waste codes: Is this waste a characteristic hazardous waste? Yes No If yes, list waste codes: List the name and title of the person making this determination: Date of this determination:

9 Kansas Department of Health and Environment Bureau of Waste Management 1000 SW Jackson, Suite 320, Topeka, Kansas Characteristic and Listed Hazardous Wastes Technical Guidance Document HW-2011-G2 Hazardous waste generators need to know which waste codes apply to their waste in order to properly manage that waste. This technical guidance document (TGD) describes how to determine waste codes for different types of waste. This guidance is not designed for every waste stream and should not be used without consulting the regulations. The Federal Regulations referred to in this document are adopted by Kansas in KAR The Environmental Protection Agency (EPA) has established two categories of hazardous wastes: characteristic and listed. A waste can be both a characteristic hazardous waste and a listed hazardous waste. Each characteristic and each listing has a waste code associated with it. These waste codes should be used by the generator on hazardous waste manifests, land disposal restriction (LDR) forms, and on any waste determination documents, such as those provided with TGD HW-2011-G1, Hazardous Waste Determinations and Documentation. Characteristic Hazardous Waste A waste can exhibit the characteristics of: Ignitability (waste code D001); Corrosivity (waste code D002); Reactivity (waste code D003); and/or Toxicity (waste codes D004 to D043). Knowledge of the process that produced the waste and/or the results of analytical testing can be used to determine if the waste is a characteristic hazardous waste. Analytical testing should be done by a laboratory certified by the Kansas Department of Health and Environment (KDHE). If there is any doubt about whether or not a waste exhibits a hazardous characteristic, it is the generator s responsibility to have the waste analyzed at least once, using appropriate tests to make an adequate waste determination. The analytical testing will only need to be repeated if the generator changes something in their process, including the source of raw materials. Page 1 of 5 The first three characteristics are fairly easy to determine: Ignitable hazardous waste has a flashpoint of less than 140 degrees Fahrenheit ( F). Corrosive hazardous waste has a ph of 0 to 2 or 12.5 to 14. Reactive hazardous waste is waste that is normally unstable, reacts violently with water, generates toxic gases when exposed to water or corrosive materials, or is capable of detonation or explosion when exposed to heat or flame. There e is no analytical test currently approved by EPA to determine if a waste is reactive. The fourth characteristic, toxicity, is more difficult to determine. EPA has set regulatory limits for 40 toxic compounds. To determine if a waste meets or exceeds these regulatory limits, a representative sample of the waste should be collected and submitted ted to a KDHE-certified laboratory. The laboratory should prepare the sample for analysis using the Toxicity Characteristic Leaching Procedure (TCLP) extraction method and analyze the sample, using EPA-approved test methods, for the contaminants listed in 40 CFR A generator can use knowledge of the process that generated the waste to reduce analytical costs. For example, if a generator knows that the process does not use pesticides, herbicides, semi-volatile organic compounds (SVOCs), or mercury, then there is no need to test for those contaminants. When the generator submits the representative sample of their waste to a KDHE- 4/11/2013

10 BWM TGD HW-2011-G2: Characteristic and Listed Hazardous Wastes certified laboratory, only two tests would be requested: TCLP Volatile Organic Compounds (VOCs) and TCLP metals minus mercury. This will be significantly less expensive than having the laboratory analyze for the entire list of TCLP compounds. The generator should maintain documentation, such as Material Safety Data Sheets (MSDS), showing that the raw materials used in the process do not contain the contaminants for which tests were not run. The analytical results received from the laboratory should be compared to the regulatory limits found in 40 CFR If the concentration of any constituent is equal to or greater than the regulatory limit, then the waste is a hazardous waste. The waste code of each constituent that meets or exceeds the regulatory limit should be used for the waste. Listed Hazardous Waste Wastes that are included in EPA s F, K, P, or U lists are hazardous wastes. Each list has a different focus and can be found in 40 CFR through F-Listed Wastes F-listed wastes are hazardous wastes from nonspecific sources. Most of the F-list is fairly easy to understand. Some examples follow. F019 is the waste code for wastewater treatment sludges from the chemical conversion coating of aluminum. If a generator uses a chemical conversion coating process for aluminum, and if the wastewater is treated on-site, then the sludge from that wastewater treatment is a listed hazardous waste with the F019 waste code. F006 is the waste code for wastewater treatment sludges from electroplating operations except from the following processes: (1) Sulfuric acid anodizing of aluminum; (2) tin plating on carbon steel; (3) zinc plating (segregated basis) on carbon steel; (4) aluminum or zinc-aluminum plating on carbon steel; (5) cleaning/stripping associated with tin, zinc and aluminum plating on carbon steel; and (6) chemical etching and milling of aluminum. Therefore, if a generator has a chrome-plating operation and the wastewater is treated on-site, the sludge from the treatment of that wastewater is a listed hazardous waste with the waste code F006. The most common F-listed waste codes used in Kansas are F001, F002, F003, F004, and F005. These are the waste codes for specific spent solvents, and they appear frequently because many wastes generated from painting operations and from parts washers contain solvents. Each of these spent solvent listings is defined by how a specific solvent is used and the percentage of a specific constituent in the solvent before it is used. Please be aware that more than one of these F-listings may apply to a single waste stream. F001, F002, F004, and F005 Waste Codes When a solvent mixture contains a total of 10% or more of one spent solvent, or a combination of spent solvents, from the F001, F002, F004, and F005 listings, then all appropriate F-listings will apply to the mixture. In order to clarify how to apply these listings, the following two scenarios are presented. Scenario 1 A generator has a parts washer with a solvent that has become too dirty to use anymore. The generator must now make a hazardous waste determination on the spent solvent so that it can be properly disposed of. The generator looks at the MSDS for the solvent and it lists: trichloroethylene (65%) and methylene chloride (35%). These solvents are found both on the F001 and F002 lists. The parts washer is not part of a degreasing (largescale cleaning) operation and therefore the F001 listing does not apply. The F002 listing does apply to this waste, since the combination of trichloroethylene and methylene chloride makes up 10% or more of the mixture (in this case 100%). Therefore, this mixture is a listed hazardous waste carrying the F002 waste code. Scenario 2 A generator uses methyl ethyl ketone (MEK) to thin paint. The waste paint is poured into a 55-gallon drum. The generator also cleans the paint gun and lines with MEK, Page 2 of 5 4/11/2013

11 BWM TGD HW-2011-G2: Characteristic and Listed Hazardous Wastes but this waste is put in a 15-gallon drum that is kept segregated from the waste paint. The generator looks at the F005 listing and sees that MEK that has been used as a solvent is a listed hazardous waste carrying the F005 waste code. Therefore the 15-gallon drum of spent solvent (MEK) is a listed hazardous waste (F005). The 55-gallon drum of waste paint is not a listed hazardous waste because the MEK was used as an ingredient in the paint; it was not used as a solvent. However, the waste paint may be a hazardous waste if it exhibits the characteristic of ignitability (D001) and/or MEK toxicity (D035). An analysis of a representative sample would be necessary to determine if the waste paint is characteristic for MEK toxicity. F003 Waste Code The definition of an F003-listed waste is more complicated. There are two ways that a spent solvent mixture can meet the F003 listing: The mixture contains only F003 constituents that are pure or technical grade; or The mixture contains one or more F003 constituents and a total of 10% or more of the other listed solvents (F001, F002, F004, and/or F005) before use. In either of the above cases, the spent solvent mixture must be ignitable (have a flashpoint of less than 140 F) at the point of generation in order for the F003 listing to apply. If the spent solvent mixture is not ignitable at the point of generation, then the listing will not apply. Below are five scenarios that demonstrate how to apply the F003 listing. Scenario 1 A generator uses a solvent for cleaning. The MSDS shows acetone at 99.9% and water at 0.1%. This would be considered a technical grade for acetone. 1. The generator looks at the F003 list and sees that acetone is on the list. 2. The generator determines that the spent solvent is ignitable because it has a flash point of less than 140 F at the point of generation. Therefore, the spent acetone will be a listed hazardous waste carrying the waste code F003 because the spent solvent is composed only of a pure or technical grade (essentially 100%) F003-listed solvent and is ignitable at the point of generation. In most painting and parts washer applications, F003-listed solvents are not used in pure or technical grade form. These solvents are usually mixed/blended with other solvents. The next three examples will show how to apply the F003 listing for a solvent mixture. Scenario 2 A generator uses a solvent for cleaning. The MSDS for the solvent shows: acetone (65%), toluene (6%), and MEK (5%). Determining the applicable waste codes can be broken down into the following steps: 1. The generator looks at the F005 list and sees that toluene and MEK are both on the list. The combined percentage of the toluene and MEK is 11%, which meets the listing definition of a total of 10% or more. Therefore, the spent solvent is a listed hazardous waste with the waste code F The generator also looks at the F003 list and sees that acetone is on the list. The generator sees that by definition the listing applies if the spent solvent contains one or more of the solvents on the F003 list (in this case, acetone) and a total of 10% or more of one or more of the solvents listed in the F001, F002, F004, and F005 lists (in this case, 11% of F005-listed solvents). Therefore, if the spent solvent is ignitable at the point of generation it will meet the definition of a F003-listed waste. 3. The generator determines that the spent solvent is ignitable because it has a flash point of less than 140 F at the point of generation. Therefore, the spent solvent meets the definition of a F003-listed waste. The spent solvent in this scenario would carry both the F003 and F005 waste codes. The important thing to remember is that the percentage of the F003-listed solvent does not matter as long as there is a total of 10% or more of the other F-listed solvents (F001, F002, F004, and/or F005) and the spent solvent is ignitable at the point of generation. Page 3 of 5 4/11/2013

12 BWM TGD HW-2011-G2: Characteristic and Listed Hazardous Wastes In the above example, if the generator had determined that the spent solvent was not ignitable at the point of generation, then the F003 listing would not have applied and the only applicable waste code would have been F005. Scenario 3 The generator from Scenario 2 recycles his solvent in a distillation unit on-site. Still bottoms (i.e. pancakes, still cakes, pucks, solids) are generated from this process. These solids will also be a listed hazardous waste carrying the F003 and F005 waste codes because the definition for both F003 and F005 listings states that they include still bottoms from the recovery of these spent solvents and spent solvent mixtures. This is the only case where it doesn t matter whether the waste is ignitable at the point of generation; the F003 listing applies entirely because of the still bottoms definition (40 CFR ). Scenario 4 A generator uses a solvent for cleaning. The MSDS for the solvent shows: acetone (65%) and water (35%). The generator looks at the F003 list and sees that acetone is on it. However, based on the MSDS, the solvent is not pure or technical grade acetone (because it does not contain essentially 100% F003-listed solvent). Also, the solvent does not contain any other F-listed (F001, F002, F004, or F005) constituents. Therefore, the spent solvent does not meet the definition of an F-listed spent solvent, and does not carry any of those listed waste codes. However, if the spent solvent is ignitable at the point of generation, it will carry the characteristic waste code for ignitability, D001. Scenario 5 A generator uses a solvent for cleaning paint brushes. The MSDS for the solvent shows: toluene (65%), methylene chloride (5%), xylene (5%), and water (25%). Determining the applicable waste codes can be broken down into the following steps: 1. The generator finds toluene on the F005 list. 2. The generator finds methylene chloride on both the F001 and the F002 lists. The F001 listing applies to the listed solvents used in large-scale industrial degreasing operations. The F002 listing applies to the listed solvents used for other applications than large-scale industrial degreasing. In this example, F002 is the applicable waste code because the generator is using the solvent to clean paint brushes, which is not large-scale, industrial degreasing. 3. The generator combines the percentages of toluene (65%) and methylene chloride (5%), for a total percentage of 70%. By both the F002 and F005 definitions, the spent solvent would be listed for both waste codes because the solvent contains 10% or more of a solvent, or a combination of solvents, listed in F001, F002, F004, and F The generator finds xylene in the F003 list. The generator sees that by definition the listing applies if the waste (spent) solvent contains one or more of the solvents on the F003 list (in this case, xylene) and a total of 10% or more of one or more of the solvents listed in the F001, F002, F004, and F005 lists (in this case 70% of F002- and F005- listed solvents). Therefore, if the spent solvent is ignitable at the point of generation it will meet the definition of a F003-listed waste. 5. The generator determines that the spent solvent is ignitable because it has a flash point of less than 140 F at the point of generation. Therefore, the spent solvent meets the definition of an F003-listed waste. The spent solvent in this scenario will carry the F002, F003, and F005 waste codes. In the above example, if the generator had determined that the spent solvent was not ignitable at the point of generation, then the F003 listing would not have applied and the only applicable waste codes would have been F002 and F005. It is important to note that on the one-time land disposal restriction (LDR) notification for a spent solvent that carries the F003 waste code, the D001 waste code must be included in addition to the F003 waste code. This ensures Page 4 of 5 4/11/2013

13 BWM TGD HW-2011-G2: Characteristic and Listed Hazardous Wastes that the spent solvent will be treated for the characteristic of ignitability. K-Listed Wastes K-listed wastes are hazardous wastes from specific sources. A generator must utilize the specific process listed in the definition in order to have a K-listed waste. An example of K- listed hazardous waste is distillation bottoms from the production of acetaldehyde from ethylene, which carries a waste code of K009. P- and U-Listed Wastes P- and U-listed wastes are discarded commercial chemical products, off-specification species, container residues, and spill clean-up materials from any of these that must be disposed for some reason. The difference between the P and U lists lies in the toxicity of the product. The acutely toxic products are on the P-list and less toxic products are on the U-list. The product will only become a waste at the point the generator no longer has a use for it and determines that it must be discarded (or if it is spilled and cleaned up). P- and U-listed hazardous wastes are unused (not spent) materials. If the discarded material is a solution, the generator should look at the active ingredient of the solution. Some common examples of P- and U-listed wastes are: Discarded nicotine patches (P075) Warfin (P001) Acetone (U002) Benzene (U019) Toluene (U220) Remember that a material must be unused to meet the definition of P- or U-listed waste. P-listed wastes are less common, but due to their acute toxicity they are regulated at a much smaller quantity than other hazardous wastes. A facility that generates or accumulates on-site as little as 2.2 pounds of P-listed hazardous waste is regulated as a Large Quantity Generator. For additional information regarding proper management of solid or hazardous waste in Kansas, you may contact the Bureau of Waste Management at (785) or the address at the top of this document, or visit the Bureau=s website at Page 5 of 5 4/11/2013

14 Other Common Wastes Lead-Acid Batteries (40 CFR 266, Subpart G or Universal Waste 40 CFR 273) Used lead-acid batteries are regulated as hazardous wastes only if they are NOT recycled (40 CFR 266, subpart G). Batteries that are recycled do not need to be counted in determining the quantity of hazardous waste generated per month, nor do they require a hazardous waste manifest when shipped off your premises. This exemption does not apply if you recycle batteries on your premises. Lead-acid batteries may also be managed under the Universal Waste rule in 40 CFR 273 and in K.A.R Asbestos (40 CFR 763) Asbestos is not a hazardous waste and is not subject to the hazardous waste regulations. Asbestoscontaining material (ACM) regulated under K.A.R (Asbestos waste disposal) may be disposed of as a special waste at a permitted municipal solid waste landfill (MSWLF) if the generator complies with the requirements of K.A.R , the special waste regulation. For more information about asbestos disposal you can contact the Special Waste Coordinator at (785) Used Oil (40 CFR 279 and K.A.R ) Used oil that is recycled for energy or material recovery is not subject to the hazardous waste regulations. Used oil that is recycled by burning in a space heater or by a used oil collector does not need to be counted in determining the quantity of hazardous waste generated per month, nor does it require a hazardous waste manifest when shipped off your premises. Used oil can be burned in oil-fired space heaters provided that: The heater burns only used oil that you generate or used oil received from household do-ityourselfers, not businesses, who generate used oil as household waste; The heater is designed to have a maximum capacity of not more than 0.5 million (500,000) Btus per hour; and The combustion gases from the heater are vented to the outside air. If you burn only your own used oil in a space heater, you do not need to notify KDHE. If you burn used oil in an industrial boiler or furnace, or send your oil to someone who is burning it, you are required to notify KDHE on the Notification of Regulated Waste Activity Form available at the KDHE BWM website (address found on the cover of this document). Used oil should never be used on the ground for any purpose including weed control. Polychlorinated Biphenyls (PCBs) (40 CFR 761) PCBs are not a hazardous waste and are not subject to the hazardous waste regulations. The use, storage and disposal of PCBs is regulated under the federal Toxic Substances Control Act (TSCA). Additional information on the storage, transportation, and disposal of PCBs may be obtained by contacting the EPA Region VII, PCB Coordinator in Kansas City at (913) Mixed Waste Mixed waste is waste that contains a radioactive component and a hazardous component. The radioactive component, which may be high-level, low-level, transuranic, or other, is subject to the Atomic Energy Act (AEA). The radioactive component is regulated by KDHE s radiation program in the Bureau of Environmental Health. The hazardous component may be either a listed hazardous waste or is a characteristic hazardous waste. The hazardous waste component is regulated by the KDHE Bureau of Waste Management (BWM). 12

15 Medical Waste Medical facilities may generate three types of wastes: infectious, radiological, and chemical. Infectious wastes are not regulated as hazardous wastes, but are regulated as solid wastes in Kansas. Guidelines in the form of Technical Guidance Documents (TGDs) for managing such wastes can be obtained from the Solid Waste Permits Section of the Bureau of Waste Management (BWM) at (785) or on the BWM website (address found on the cover of this document). Radiological wastes that are not mixed wastes are regulated by KDHE s radiation program in the Bureau of Environmental Health. Medical facilities that generate characteristic or listed hazardous wastes must comply with the same requirements as other generators of hazardous wastes. Empty Containers (40 CFR 261.7) Containers or container liners that have held hazardous materials are not regulated as hazardous wastes if the containers or liners are empty. A container is considered empty according to the requirements of 40 CFR if: All wastes that can be removed have been removed by pouring, pumping, and aspirating, and No more than one inch of residue remains in the container or liner, or No more than 3.0 percent by weight of the total capacity of the container remains in the container or liner if the container is equal to or less than 110 gallons in size, or No more than 0.3 percent by weight of the total capacity of the container remains in the container or liner if the container is greater than 110 gallons in size. Any containers that contained P-listed materials or wastes must be triple-rinsed using an appropriate solvent before they are considered empty. Unless exempt, rinsates (wash-out wastes) from P-listed containers must be managed as hazardous wastes. Universal Waste (40 CFR 273 and K.A.R ) Kansas has adopted no specific state requirements for universal wastes. The most common universal wastes are mercury-containing lamps such as fluorescent, mercury vapor, or high intensity discharge (HID) lamps. The provisions of 40 CFR 273 reduce many of the stringent hazardous waste regulations and allow universal wastes to be more easily collected, transported, and recycled or disposed. For more information about spent mercury-containing lamps and universal wastes, please refer to the KDHE BWM Technical Guidance Documents (TGDs) titled Spent Fluorescent Lamps Containing Mercury (HW 95-01) and Notification Requirements for Large Quantity Handlers of Universal Waste (HW 01-01), respectively. The TGDs are available on the BWM website (address found on the cover of this document). V. What Quantities of Hazardous Waste are Regulated? After a generator determines which wastes are hazardous wastes, the next step is to determine the generation rate and maximum quantities that are accumulated. The generation rate is determined by adding together the total quantity of hazardous waste generated from all sources each calendar month. In determining the generation rate, the actual amount of waste generated each calendar month is used, not an average over a number of months. 13

16 In determining the quantity of hazardous waste generated each calendar month, a generator does not need to include the following: Hazardous waste when it is removed from on-site storage; Hazardous waste that is recycled on-site and has already been counted once in that calendar month (See Technical Guidance Document HW-2011-G3, Determining the Hazardous Waste Generation Rate for On-Site Solvent Recycling) Lead-acid batteries that are recycled; Universal wastes managed according to 40 CFR 273. Used oil regulated under 40 CFR 279 VI. Generator Classifications Kansas regulations define four categories (classes) of hazardous waste generators whose requirements are described in detail below. A generator must determine which category his or her facility is classified in order to determine which regulations must be followed. It should be noted that a generator may change status from one category to another depending upon generation rates and accumulated quantities. The four categories of generators in Kansas are: Conditionally Exempt Small Quantity Generator (CESQG) Kansas Small Quantity Generator (KSQG) Small Quantity Generator (SQG) Large Quantity Generator (LQG) VII. Summary of Generator Requirements This summary is not meant to replace the regulations and is not a complete list of all regulatory requirements for generators. This summary is meant as a brief reference tool to assist generators with compliance. A. Conditionally Exempt Small Quantity Generator (CESQG) Requirements To be classified as a CESQG, a generator must meet the following criteria: Generate less than 25 kilograms (55 pounds) of hazardous waste in a single calendar month. [Different than EPA] Generate and accumulate less than 1 kilogram (2.2 pounds) of acutely hazardous waste or 100 kilograms (220 pounds) of other wastes listed in 40 CFR 261.5(e) in a single calendar month. [Different than EPA] 14

17 CESQG GENERAL REQUIREMENTS Must make a hazardous waste determination using one of the methods described in 40 CFR If analytical testing will be conducted, the generator must use a laboratory certified by KDHE. [Different than EPA] Never exceed 1,000 kilograms (2,200 pounds) of hazardous waste on-site. If that amount is exceeded, then the CESQG becomes subject to SQG standard. Never generate or accumulate 1 kilogram (2.2 pounds) or more of acutely hazardous waste onsite. If that amount is exceeded, then the CESQG becomes subject to LQG standards. [Different than EPA] NON-ACCUMULATING CESQG DISPOSAL OPTIONS A CESQG that does not accumulate their waste on-site, meaning that they dispose of their waste as it is generated, is considered a non-accumulating CESQG. Non-accumulating CESQGs may send less than 25 kilograms (55 pounds) of hazardous waste to an off-site disposal facility meeting the following requirements: A Kansas household hazardous waste (HHW) facility that has a permit issued by the secretary and follows all associated regulations and policies; or An off-site treatment, storage or disposal facility (TSDF), if located in the U.S., that is: Permitted by KDHE, another authorized state, or EPA as a hazardous waste TSDF; or Permitted, licensed, or registered by a state to manage municipal solid waste (MSW) in a landfill (subject to 40 CFR Part 258); All Kansas MSW landfills meet this requirement; or A non-msw landfill that meets all state and federal requirements for accepting CESQG waste. These landfills do not exist in Kansas, but may be available in bordering states. All non-msw landfills (industrial landfills, construction and demolition landfills, and monofills) in Kansas are prohibited from taking any amount of hazardous waste; or A facility which o Beneficially uses or reuses, or legitimately recycles or reclaims the waste; or o Treats the waste prior to beneficial use or reuse, or legitimate recycling or reclamation; or For universal waste managed under part 273 of this chapter, a universal waste handler or destination facility subject to the requirements of part 273 of this chapter. CESQG accumulating less than 25 kilograms (55 pounds) of hazardous waste on-site STOP HERE. If a CESQG sends 25 kilograms (55 pounds) or more of hazardous waste off-site at any one time, that waste may only be sent to: A Kansas household hazardous waste (HHW) facility that has a permit issued by the secretary and follows all associated regulations and policies; or An off-site treatment, storage or disposal facility (TSDF), if located in the U.S., that is: Permitted by KDHE, another authorized state, or EPA as a hazardous waste TSDF; or A facility which o Beneficially uses or reuses, or legitimately recycles or reclaims the waste; or o Treats the waste prior to beneficial use or reuse, or legitimate recycling or reclamation; or For universal waste managed under part 273 of this chapter, a universal waste handler or destination facility subject to the requirements of part 273 of this chapter. 15

18 CESQG RECORD KEEPING REQUIREMENTS Maintain all monthly inspection logs for a minimum of 3 years. [Different than EPA] CESQG CONTAINER MANAGEMENT REQUIREMENTS If a CESQG accumulates 25 kilograms (55 pounds) or more of hazardous waste on-site, then they must meet the following container management requirements: Conduct monthly inspections of hazardous waste storage areas. [Different than EPA] At a minimum, the inspections should be documented in a log and should include the date and time of the inspection, the name of the inspector, a notation of the observations made, and the date and nature of any repairs or other remedial actions. [Different than EPA] Clearly mark the date upon which each period of accumulation begins and ensure that the date is visible for inspection on each container. Clearly label or mark each container with the words Hazardous Waste. Each container must be in good condition. Each container must be compatible with its contents. Each container must be kept closed except when adding or removing waste. Hazardous wastes must not be stored near other hazardous wastes or materials with which it is incompatible. Pre-transport requirements of 40 CFR 262 subpart C except (Accumulation time) as follows: All waste transported or offered for transport off-site must be packaged in accordance with the applicable U.S. Department of Transportation (DOT) regulations on packaging under 49 CFR parts 173, 178, and 179. All waste transported or offered for transport off-site must be labeled in accordance with the applicable DOT regulations on hazardous materials under 49 CFR part 172. All waste transported or offered for transport off-site must be marked in accordance with the applicable DOT regulations under 49 CFR part 172. Before transporting hazardous waste or offering hazardous waste for transportation offsite, the generator must placard or offer the initial transporter the appropriate placards according to DOT regulations for hazardous materials under 49 CFR part 172, subpart F. CESQG TANKS If a CESQG accumulates 25 kilograms (55 pounds) or more of hazardous waste on-site, then they must meet the following tank management requirements: Clearly mark the date upon which each period of accumulation begins and ensure that the date is visible for inspection on each tank. Clearly label or mark each tank with the words Hazardous Waste. If 25 kilograms (55 pounds) or more of hazardous waste is accumulated in one or more tanks then the CESQG must also comply with 40 CFR

19 B. Kansas Small Quantity Generator (KSQG) Requirements To be classified as a Kansas Small Quantity Generator (KSQG), a generator must meet the following criteria: Generate 25 kilograms (55 pounds) or more, but no more than 100 kilograms (220 pounds) of hazardous waste in a single calendar month; Generate and accumulate less than 1 kilogram (2.2 pounds) of acutely hazardous waste or 100 kilograms (220 pounds) of other wastes listed in 40 CFR 261.5(e) in a single calendar month. KSQG GENERAL REQUIREMENTS Must make a hazardous waste determination using one of the methods described in 40 CFR If analytical testing will be conducted, the generator must use a laboratory certified by KDHE. [Different than EPA] Must obtain an EPA Identification Number from KDHE. [Different than EPA] Must update information on the Notification of Regulated Waste Activity form as it changes (within 60 days of change). [Different than EPA] Never exceed 1,000 kilograms (2,200 pounds) of hazardous waste on-site. If that amount is exceeded, then the KSQG becomes subject to SQG standards. Never accumulate 1 kilogram (2.2 pounds) or more of acutely hazardous waste on-site. If that amount is exceeded, then the KSQG becomes subject to LQG standards for that acutely hazardous waste. [Different than EPA] Must use a transporter and TSDF who has an EPA Identification Number, unless transporting their own waste to a reclamation facility or Kansas household hazardous waste (HHW) facility that has a permit issued by the secretary and follows all associated regulations and policies. [Different than EPA] Must use a transporter who has properly registered with KDHE unless transporting their own waste to a reclamation facility or Kansas HHW facility that has a permit issued by the secretary and follows all associated regulations and policies. [Different than EPA] Must use a hazardous waste manifest pursuant to 40 CFR 262 subpart B unless transporting their own waste to a reclamation facility or Kansas HHW facility that has a permit issued by the secretary and follows all associated regulations and policies. [Different than EPA] Generators exporting or importing hazardous waste must follow the requirements of 40 CFR 262 Subparts E and F. Meet of the Land Disposal Restriction requirements found in 40 CFR 268.7(a)(5) if treating hazardous waste on-site in containers or tanks. [Different than EPA] Can use a tolling agreement if the requirements of 40 CFR (e) are met. KSQG RECORDKEEPING, REPORTING, AND FEE REQUIREMENTS Maintain a signed copy of each hazardous waste manifests on-site for a minimum of three (3) years. Maintain records of any test results, waste analyses, or other waste determinations made in accordance with 40 CFR for a minimum of three years from the date that the waste was last treated and/or disposed. Follow the exception reporting requirements of 40 CFR (b) if a manifest is not received from the designated facility (TSDF) within 60 days of the date the waste was accepted by the first transporter. [Different than EPA] Prepare and submit a report to the secretary by April 1 of each year that indicates your generator status. [Different than EPA] 17

20 Maintain a copy of the required report due on April 1 for a minimum of three (3) years from the date the report was due. [Different than EPA] Submit the appropriate monitoring fee as required in KAR with the required report due on April 1. [Different than EPA] Maintain a copy of all inspection logs for a minimum of three (3) years. [Different than EPA] Maintain a copy of all training records for a minimum of three (3) years. [Different than EPA] KSQG CONTAINER MANAGEMENT REQUIREMENTS Each container must be in good condition. Each container must be compatible with its contents. Each container must be kept closed except when adding or removing waste. Hazardous waste must not be stored near other hazardous wastes or materials with which it is incompatible. Conduct monthly inspections of hazardous waste storage areas. At a minimum, the inspections should be documented in a log and should include the date and time of the inspection, the name of the inspector, a notation of the observations made, and the date and nature of any repairs or other remedial actions. Clearly mark the date upon which each period of accumulation begins and ensure that the date is visible for inspection on each container. Clearly label or mark each container with the words Hazardous Waste. Meet the pre-transport requirements as follows. All waste transported or offered for transport off-site must be packaged in accordance with the applicable U.S. Department of Transportation (DOT) regulations on packaging under 49 CFR parts 173, 178, and 179. All waste transported or offered for transport off-site must be labeled in accordance with the applicable DOT regulations on hazardous materials under 49 CFR part 172. All waste transported or offered for transport off-site must be marked in accordance with the applicable DOT regulations under 49 CFR part 172. Before transporting hazardous waste or offering hazardous waste for transportation offsite, the generator must placard or offer the initial transporter the appropriate placards according to DOT regulations for hazardous materials under 49 CFR part 172, subpart F. KSQG Satellite Accumulation A KSQG may accumulate 55 gallons or less, in no more than one container, of each type of hazardous waste (or one quart or less, in no more than one container, of each type of acutely hazardous waste listed in 40 CFR (e) at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or interim status and without this waste becoming subject to accumulation time limits provided that the following conditions are met: [Different than EPA] Containers are in good condition; Containers are compatible with the waste they are holding; Containers are kept closed except when adding or removing waste; Containers are clearly marked with the words Hazardous Waste ; [Different than EPA] Mark the accumulation start date on the container when the 55-gallon limit is exceeded (or the container otherwise no longer meets the definition of a satellite container); and Move the container to storage (or manage it as a storage container at that location) within 3 days of the container no longer meeting the definition of a satellite container. 18

21 KSQG Tanks Clearly mark the date upon which each period of accumulation begins and ensure that the date is visible for inspection on each tank. Clearly label or mark each tank with the words Hazardous Waste. Treatment or storage of hazardous waste in tanks must comply with 40 CFR (b). Contents of the tank should not cause it to corrode or otherwise fail before the end of its intended life. Uncovered tanks must be operated to ensure at least 60 centimeters (2 feet) of freeboard, unless the tank is equipped with a containment structure (e.g., dike or trench), a drainage control system, or a diversion structure (e.g., standby tank) with a capacity that equals or exceeds the volume of the top 60 centimeters (2 feet) of the tank. Where hazardous waste is continuously fed into a tank, the tank must be equipped with a means to stop this in-flow. Generators who accumulate hazardous waste in tanks must: Conduct daily and/or weekly inspections of the tank and its systems as required in 40 CFR (c) and (d). Upon closure, remove all hazardous waste from tanks, discharge control equipment, and discharge confinement structures. Follow the special requirements found in 40 CFR (g) for ignitable or reactive waste. Follow the special requirements found in 40 CFR (h) for incompatible waste. KSQG PREPAREDENSS AND PREVENTION The facility must be maintained and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. The facility must be equipped with the following unless none of the hazards posed by waste handled at the facility could require a particular kind of equipment specified below: An internal communications or alarm system capable of providing immediate emergency instruction (voice or signal) to facility personnel; A device such as a telephone (immediately available at the scene of operations) or a handheld two-way radio, capable of summoning emergency assistance from local police departments, fire departments, or state or local emergency response teams; Portable fire extinguishers, fire control equipment (including special extinguishing equipment, such as that using foam, inert gas, or dry chemicals), spill control equipment, and decontamination equipment; and; Water at adequate volume and pressure to supply water hose streams, or foam producing equipment, or automatic sprinklers, or water spray systems. The facility communications or alarm systems, fire protection equipment, spill control equipment, and decontamination equipment, where required, must be tested and maintained as necessary to assure its proper operation in time of emergency. Whenever hazardous waste is being poured, mixed, spread, or otherwise handled, all personnel involved in the operation must have immediate access to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee (unless such a device is not required under 40 CFR ). Aisle space must be maintained to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency. The generator must attempt to make the following arrangements, as appropriate for the type of waste handled at the facility and the potential need for the services of these organizations. If state 19

22 or local authorities refuse to enter into such an agreement, then the generator must document the refusal in the operating record: Arrangements to familiarize police, fire departments, and emergency response teams with the layout of the facility, properties of hazardous waste handled at the facility and associated hazards, places where facility personnel would normally be working, entrances to roads inside the facility, and possible evacuation routes; Where more than one police and fire department might respond to an emergency, agreements designating primary emergency authority to a specific police and a specific fire department, and agreements with any others to provide support to the primary emergency authority; Agreements with state emergency response teams, emergency response contractors, and equipment suppliers; and Agreements to familiarize local hospitals with the properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions, or releases at the facility. Must have an emergency coordinator on-site or on call (able to be on-site within 30 minutes) at all times. This emergency coordinator must be able to coordinate all emergency response measures specified below. The following information must be posted next to at least one telephone: The name and telephone number of the emergency coordinator; Location of fire extinguishers and spill control material, and, if present, fire alarm; and The telephone number of the fire department, unless the facility has a direct alarm. If the generator relies solely on cell phones: o The information listed above must be posted on walls so that they can be readily seen by employees; o Employees shall be trained on the locations of these postings; and o Management personnel shall have these numbers programmed into their cell phones. The emergency coordinator must respond to any emergencies that arise and meet the response requirements of 40 CFR (d)(5)(iv). KSQG TRAINING Each KSQG shall ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies. This training should be: [Different than EPA] Provided within 6 months of hire (or transfer to a new position); Be repeated at least annually; and Documented by recording all of the following: The name of the employee; Date of the training; A list of the topics covered in the training. Training records must be maintained for a minimum of 3 years. 20

23 C. Small Quantity Generator (SQG) Requirements To be classified as a SQG, a generator must meet the following criteria: Generate more than 100 kilograms (220 pounds) but less than 1,000 kilograms (2,200 pounds) of hazardous waste in a single calendar month; and Generate and accumulate less than 1 kilogram (2.2 pounds) of acutely hazardous waste in a calendar month. SQG GENERAL REQUIREMENTS Never exceed 6,000 kilograms (13,200 pounds) of hazardous waste on-site. If that amount is exceeded, then the SQG becomes subject to TSDF permitting requirements and standards for all of their hazardous waste. Never exceed 1 kilogram (2.2 pounds) of acutely hazardous waste on-site. If that amount is exceeded, then the SQG becomes subject to LQG standards for that acutely hazardous waste. [Different than EPA] Must make a hazardous waste determination using one of the methods described in 40 CFR If analytical testing will be conducted, the generator must use a laboratory certified by KDHE. [Different than EPA] Must obtain an EPA identification Number from KDHE. Store hazardous waste on-site for 180 days or less (and not exceed 6,000 kilograms) or 270 days or less if the generator must transport hazardous waste more than 200 miles for off-site treatment, storage or disposal (If the generator exceeds the 180- or 270-day requirement, then they become subject to all permitting requirements of a TSDF). Must update information on the Notification of Regulated Waste Activity form as it changes (within 60 days of change). [Different than EPA] Must use a transporter and TSDF who has an EPA Identification Number. Must use a transporter who has properly registered with KDHE. [Different than EPA] Must use a hazardous waste manifest pursuant to 40 CFR 262 subpart B. Generators exporting or importing hazardous waste must follow the requirements of 40 CFR Subparts E and F. Meet all of the Land Disposal Restriction requirements as referenced in KAR Can use a tolling agreement if the requirements of 40 CFR (e) are met. SQG RECORDKEEPING, REPORTING, AND FEE REQUIREMENTS Maintain a signed copy of each hazardous waste manifest on-site for a minimum of three (3) years. Maintain records of any test results, waste analyses, or other waste determinations made in accordance with 40 CFR for a minimum of three years from the date that the waste was last treated and/or disposed. Follow the exception reporting requirements of 40 CFR (b) if a manifest is not received from the designated facility (TSDF) within 60 days of the date the waste was accepted by the first transporter. Prepare and submit a report to the secretary by April 1 of each year that indicates your generator status. [Different than EPA] Maintain a copy of the required report due on April 1 for a minimum of three (3) years from the date the report was due. [Different than EPA] Submit the appropriate monitoring fee as required in KAR with the required report due on April 1. [Different than EPA] 21

24 Maintain copies of all inspection logs for a minimum of three (3) years. [Different than EPA] Maintain a copy of all training records for a minimum of three (3) years. [Different than EPA] SQG CONTAINER MANAGEMENT REQUIREMENTS Each container must be in good condition. Each container must be compatible with its contents. Each container must be kept closed except when adding or removing waste. Hazardous wastes must not be stored near other hazardous wastes or materials with which it is incompatible. Weekly inspections must be conducted for all areas where hazardous waste is stored. At a minimum, the inspections should be documented in a log and should include the date and time of the inspection, the name of the inspector, a notation of the observations made, and the date and nature of any repairs or other remedial actions. Clearly mark the date upon which each period of accumulation begins and ensure that the date is visible for inspection on each container. Clearly label or mark each container with the words Hazardous Waste. Meet the pre-transport requirements as follows: All waste transported or offered for transport off-site must be packaged in accordance with the applicable U.S. Department of Transportation (DOT) regulations on packaging under 49 CFR parts 173, 178, and 179. All waste transported or offered for transport off-site must be labeled in accordance with the applicable DOT regulations on hazardous materials under 49 CFR part 172. All waste transported or offered for transport off-site must be marked in accordance with the applicable DOT regulations under 49 CFR part 172. Before transporting hazardous waste or offering hazardous waste for transportation offsite, the generator must placard or offer the initial transporter the appropriate placards according to DOT regulations for hazardous materials under 49 CFR part 172, subpart F. SQG Satellite Accumulation A SQG may accumulate 55 gallons or less, in no more than one container, of each type of hazardous waste (or one quart or less, in no more than one container, of each type of acutely hazardous waste listed in 40 CFR (e)) at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or interim status and without this waste becoming subject to accumulation time limits provided the following conditions are met: [Different than EPA] Containers are in good condition; Containers are compatible with the waste they are holding; Containers are always closed except when adding or removing waste; Containers are clearly marked with the words Hazardous Waste ; [Different than EPA] Mark the accumulation start date on the container when the 55-gallon limit is exceeded (or the container otherwise no longer meets the definition of a satellite container); and Move the container to storage (or manage it as a storage container at that location) within 3 days of the container no longer meeting the definition of a satellite container. 22

25 SQG Tanks Clearly mark the date upon which each period of accumulation begins and ensure that the date is visible for inspection on each tank. Clearly label or mark each tank with the words Hazardous Waste. Treatment or storage of hazardous waste in tanks must comply with 40 CFR (b). Contents of the tank should not cause it to corrode or otherwise fail before the end of its intended life. Uncovered tanks must be operated to ensure at least 60 centimeters (2 feet) of freeboard, unless the tank is equipped with a containment structure (e.g., dike or trench), a drainage control system, or a diversion structure (e.g., standby tank) with a capacity that equals or exceeds the volume of the top 60 centimeters (2 feet) of the tank. Where hazardous waste is continuously fed into a tank, the tank must be equipped with a means to stop this in-flow. Generators who accumulate between 100 and 1,000 kilograms (220 and 2,200 pounds) per month of hazardous waste in tanks, must: Conduct daily and/or weekly inspections of the tank and its systems as required in 40 CFR (c) and/or (d). Upon closure, remove all hazardous waste from tanks, discharge control equipment, and discharge confinement structures. Follow the special requirements found in 40 CFR (g) for ignitable or reactive waste. Follow the special requirements found in 40 CFR (h) for incompatible waste. SQG PREPAREDENSS AND PREVENTION The facility must be maintained and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. The facility must be equipped with the following unless none of the hazards posed by waste handled at the facility could require a particular kind of equipment specified below: An internal communications or alarm system capable of providing immediate emergency instruction (voice or signal) to facility personnel; A device such as a telephone (immediately available at the scene of operations) or a handheld two-way radio, capable of summoning emergency assistance from local police departments, fire departments, or State or local emergency response teams; Portable fire extinguishers, fire control equipment (including special extinguishing equipment, such as that using foam, inert gas, or dry chemicals), spill control equipment, and decontamination equipment; and; Water at adequate volume and pressure to supply water hose streams, or foam producing equipment, or automatic sprinklers, or water spray systems. The facility communications or alarm systems, fire protection equipment, spill control equipment, and decontamination equipment, where required, must be tested and maintained as necessary to assure its proper operation in time of emergency. Whenever hazardous waste is being poured, mixed, spread, or otherwise handled, all personnel involved in the operation must have immediate access to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee (unless such a device is not required under 40 CFR ). Aisle space must be maintained to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency. 23

26 The generator must attempt to make the following arrangements, as appropriate for the type of waste handled at his facility and the potential need for the services of these organizations. If state or local authorities refuse to enter into such an agreement, then the generator must document the refusal in the operating record: Arrangements to familiarize police, fire departments, and emergency response teams with the layout of the facility, properties of hazardous waste handled at the facility and associated hazards, places where facility personnel would normally be working, entrances to roads inside the facility, and possible evacuation routes; Where more than one police and fire department might respond to an emergency, agreements designating primary emergency authority to a specific police and a specific fire department, and agreements with any others to provide support to the primary emergency authority; Agreements with State emergency response teams, emergency response contractors, and equipment suppliers; and Agreements to familiarize local hospitals with the properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions, or releases at the facility. Must have an emergency coordinator on-site or on call (able to be on-site within 30 minutes) at all times. This emergency coordinator must be able to coordinate all emergency response measures specified below. The following information must be posted next to at least one telephone: The name and telephone number of the emergency coordinator; Location of fire extinguishers and spill control material, and, if present, fire alarm; and The telephone number of the fire department, unless the facility has a direct alarm. If the generator relies solely on cell phones: o The information listed above must be posted on walls so that they can be readily seen by employees; o Employees shall be trained on the locations of these postings; and o Management personnel shall have these numbers programmed into their cell phones. The emergency coordinator must respond to any emergencies that arise and meet the response requirements of 40 CFR (d)(5)(iv). SQG TRAINING Each SQG shall ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies. This training should be: [Different than EPA] Provided within 6 months of hire (or transfer to a new position); Be repeated at least annually; and Documented by recording all of the following: The name of the employee; Date of the training; A list of the topics covered in the training. Training records must be maintained for a minimum of 3 years. 24

27 D. Large Quantity Generator (LQG) Requirements To be classified as a LQG, a generator must meet the following criteria: Generate 1,000 kilograms (2,200 pounds) or more of hazardous waste in a calendar month; or Generate or accumulate 1 kilogram (2.2 pounds) or more of acutely hazardous waste or 100 kilograms (220 pounds) or more of other wastes listed in 40 CFR 261.5(e) in a single calendar month. LQG GENERAL REQUIREMENTS Must make a hazardous waste determination using one of the methods described in 40 CFR If analytical testing will be conducted, the generator must use a laboratory certified by KDHE. [Different than EPA] Must obtain an EPA identification Number from KDHE. Store hazardous waste on-site for 90 days or less. One 30-day extension can be granted at the discretion of KDHE. If the generator exceeds the 90 day requirement without being granted an extension by KDHE, then they become subject to all permitting requirements of a TSDF. Must update information on the Notification of Regulated Waste Activity form as it changes (within 60 days of change). [Different than EPA] Must use a transporter and TSDF who has an EPA Identification Number. Must use a transporter who has properly registered with KDHE. [Different than EPA] Must use a hazardous waste manifest pursuant to 40 CFR subpart B. Meet all of the Land Disposal Restriction requirements as referenced in KAR Generators exporting or importing hazardous waste must follow the requirements of 40 CFR Subparts E and F. LQG RECORDKEEPING, REPORTING AND FEE REQUIREMENTS Maintain a signed copy of each hazardous waste manifest on-site for a minimum of three (3) years. Maintain records of any test results, waste analyses, or other waste determinations made in accordance with 40 CFR for a minimum of three years from the date that the waste was last treated and/or disposed. Follow the exception reporting requirements of 40 CFR (a) if a manifest is not received within 35 days of the date the waste was accepted by the first transporter. These requirements include contacting the transporter and designated facility to locate the waste and obtaining a copy of the manifest with the signature from the designated facility. It may also include filing an exception report with KDHE if the signed copy of the manifest is not received within 45 days of the date the waste was accepted by the initial transporter. Follow the biennial reporting requirements of 40 CFR Prepare and submit a report to the secretary by March 1 of each year that indicates your generator status. [Different than EPA] Maintain a copy of the required report due on March 1 for a minimum of three (3) years from the date the report was due. [Different than EPA] Submit the appropriate monitoring fee as required in KAR (g) with the required report due on March 1. [Different than EPA] Maintain copies of all inspection logs for a minimum of three (3) years. [Different than EPA] 25

28 Maintain all of the following records for all employees whose job responsibilities include managing hazardous waste as required by 40 CFR : The job title for each position; A written job description for each position, which must include the requisite skill, education, or other qualifications, and hazardous waste duties of facility personnel assigned to each position; A written description of the type and amount of both introductory and continuing training that will be given to each person; Records that document the training or job experience required; Training records must be maintained for current employees until closure of the facility, and on former employees for 3 years from the date employee last worked at the facility. Personnel training records may accompany personnel transferred within the same company. LQG CONTAINER MANAGEMENT REQUIREMENTS Each container must be in good condition. Each container must be compatible with its contents. Each container must be kept closed except when adding or removing waste. Hazardous wastes must not be stored near other hazardous wastes or materials with which it is incompatible. Weekly inspections must be conducted for all areas where hazardous waste is stored. At a minimum, the inspections should be documented in a log and should include the date and time of the inspection, the name of the inspector, a notation of the observations made, and the date and nature of any repairs or other remedial actions. Clearly mark the date upon which each period of accumulation begins and ensure that the date is visible for inspection on each container. Clearly label or mark each container with the words Hazardous Waste. Meet the pre-transport requirements as follows: All waste transported or offered for transport off-site must be packaged in accordance with the applicable U.S. Department of Transportation (DOT) regulations on packaging under 49 CFR parts 173, 178, and 179. All waste transported or offered for transport off-site must be labeled in accordance with the applicable DOT regulations on hazardous materials under 49 CFR part 172. All waste transported or offered for transport off-site must be marked in accordance with the applicable DOT regulations under 49 CFR part 172. Before transporting hazardous waste or offering hazardous waste for transportation offsite, the generator must placard or offer the initial transporter the appropriate placards according to DOT regulations for hazardous materials under 49 CFR part 172, subpart F. Comply with the requirements of 40 CFR subparts AA, BB, and CC. LQG Satellite Accumulation Any generator may accumulate 55 gallons or less, in no more than one container, of each type of hazardous waste (or one quart or less, in no more than one container, of each type of acutely hazardous waste listed in 40 CFR (e)) at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or interim status and without this waste becoming subject to accumulation time limits provided: [Different than EPA] Containers are in good condition; Containers are compatible with the waste they are holding; Containers are always closed except when adding or removing waste; 26

29 Containers are clearly marked with the words Hazardous Waste ; [Different than EPA] Mark the accumulation start date on the container when the 55-gallon limit is exceeded (or the container otherwise no longer meets the definition of a satellite container); and Move the container to storage (or manage it as a storage container at that location) within 3 days of the container no longer meeting the definition of a satellite container. LQG Tanks Clearly mark the date upon which each period of accumulation begins and ensure that the date is visible for inspection on each tank. Clearly label or mark each tank with the words Hazardous Waste. LQGs storing hazardous waste in tanks must comply with the applicable requirements of 40 CFR 265 subparts J, AA, BB, and CC of 40 CFR, except Sections (c) and Daily inspections must be conducted for all tank systems holding hazardous waste. o At a minimum, the inspections should be documented in a log and should include the date and time of the inspection, the name of the inspector, a notation of the observations made, and the date and nature of any repairs or other remedial actions. LQG PREPAREDNESS AND PREVENTION The facility must be maintained and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. The facility must be equipped with the following unless none of the hazards posed by waste handled at the facility could require a particular kind of equipment specified below: An internal communications or alarm system capable of providing immediate emergency instruction (voice or signal) to facility personnel; A device such as a telephone (immediately available at the scene of operations) or a handheld two-way radio, capable of summoning emergency assistance from local police departments, fire departments, or State or local emergency response teams; Portable fire extinguishers, fire control equipment (including special extinguishing equipment, such as that using foam, inert gas, or dry chemicals), spill control equipment, and decontamination equipment; and; Water at adequate volume and pressure to supply water hose streams, or foam producing equipment, or automatic sprinklers, or water spray systems. The facility communications or alarm systems, fire protection equipment, spill control equipment, and decontamination equipment, where required, must be tested and maintained as necessary to assure its proper operation in time of emergency. Whenever hazardous waste is being poured, mixed, spread, or otherwise handled, all personnel involved in the operation must have immediate access to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee (unless such a device is not required under 40 CFR ). Aisle space must be maintained to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency. The generator must attempt to make the following arrangements, as appropriate for the type of waste handled at his facility and the potential need for the services of these organizations. If state or local authorities refuse to enter into such an agreement, then the generator must document the refusal in the operating record: Arrangements to familiarize police, fire departments, and emergency response teams with the layout of the facility, properties of hazardous waste handled at the facility and associated 27

30 hazards, places where facility personnel would normally be working, entrances to roads inside the facility, and possible evacuation routes; Where more than one police and fire department might respond to an emergency, agreements designating primary emergency authority to a specific police and a specific fire department, and agreements with any others to provide support to the primary emergency authority; Agreements with State emergency response teams, emergency response contractors, and equipment suppliers; and Agreements to familiarize local hospitals with the properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions, or releases at the facility. The LQG must comply with the requirements of 40 CFR 265 subpart D, Contingency Plan and Emergency Procedures. LQG TRAINING The LQG must comply with the personnel training requirements of 40 CFR as required by 40 CFR (a)(4) and KAR , including all of the following: Facility personnel must successfully complete a program of classroom instruction or on-the-job training that teaches them to perform their hazardous waste management duties. This program must be directed by a person trained in hazardous waste management procedures, and must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed. At a minimum, the training program must be designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where applicable: Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment; Key parameters for automatic waste feed cut-off systems; Communications or alarm systems; Response to fires or explosions; Response to ground-water contamination incidents; and Shutdown of operations. For facility employees that receive emergency response training pursuant to OSHA regulation 29 CFR (p)(8) and (q), the facility is not required to provide separate emergency response training pursuant to this section, provided that the overall facility training meets all the requirements of this section. Personnel must complete the training program within six months of hire (or transferring to a new position managing hazardous waste) and cannot work unsupervised until the training is completed. Personnel must receive annual training after the initial training is completed. 28

31 VIII. Land Disposal Restrictions (40 CFR 268) and Hazardous Waste Manifesting (40 CFR 262) Kansas has adopted no specific state requirements for Land Disposal Restrictions (LDR) or hazardous waste manifests. Kansas also does not require that copies of manifests be submitted to KDHE at the time of shipment, which is a requirement in some other states. In Kansas, most generators use a disposal contractor to transport and dispose of their hazardous waste. These contractors must be registered with KDHE if they are transporting hazardous waste in or through Kansas. Most generators rely on these contractors to complete the necessary paperwork for shipping their hazardous waste to the disposal facility. The required paperwork generally includes the LDR and the manifest. It is in the best interest of the generator that they have someone signing the manifest who is familiar with the Kansas Hazardous Waste Program and understands what they are signing and verifies that the information on the manifest and LDR are correct before signing. It is also important that generators retain their copies of these documents for the required amount of time for their generator status (see Generator Recordkeeping requirements in the previous sections). The manifest is used to track the waste from the point of generation (facility where it was generated) to the point where it is finally treated to render it non-hazardous and/or disposed. This final point is generally a permitted treatment/storage/disposal facility (TSDF). This management system is commonly referred to as the cradle-to-grave system and the manifest ensures that the generator is able to track their waste to that final point. When the generator signs the manifest, a copy will be provided to them to be retained until they receive the final copy in the mail from the TSDF showing the final signature documenting that the waste was received at the final destination. It is this final copy that must be retained under the recordkeeping requirements. If a generator does not receive that final copy they must begin trying to locate their waste by contacting the transporter and possibly the final destination facility. If the generator cannot locate their waste, then they should contact KDHE and file an exception report. KDHE will then assist in finding the waste. There are regulatory time limits for exception reporting and the amount of time will depend on the generator s classification (i.e. KSQG, SQG, or LQG). The LDR system was created by EPA to ensure that wastes are properly treated before being land disposed to prevent contaminants from leaving the site and/or contaminating the environment. Understanding the entire LDR system and all of its requirements can be difficult. As previously stated, KDHE recognizes that most generators in Kansas utilize a contractor for this service. It is important that the generator understand the LDR requirements and the forms that their contractors are using to document that their waste is in compliance with the LDR requirements. The generator should ensure that they have a copy of their most recent LDR notification for each waste stream, for each TSDF used for that waste stream. The LDR should include all waste codes assigned to that hazardous waste and analytical data or other information about underlying constituents in the waste. EPA changed the LDR requirements a few years ago to say that each generator only needed to send one LDR notice to each TSDF for each waste stream. If the generator (or contractor) chooses to send an LDR notice with each shipment of waste, then each new LDR used will supersede the previous one. 29

32 IX. Choosing a Hazardous Waste Management Facility and/or Hazardous Waste Transporter/Contractor Choosing a hazardous waste management facility (TSDF) and/or a hazardous waste transporter (transporter) can be daunting. There are many choices in most Kansas communities and many factors should be considered. The hazardous waste regulations are cradle to grave, meaning that the generator can retain liability for the waste long after it has been disposed. It is therefore imperative that generators choose contractors that will help them be in compliance with the regulatory requirements and that will ensure that their waste is properly managed, treated, and disposed. If possible, the generator should try to make a personal visit to the TSDF and meet with potential transporters. It is also a good idea to contact the regulatory agencies in the states where the facilities are located to ensure that the transporter and TSDF do not have major compliance problems in their home states. At a minimum, contact KDHE s Bureau of Waste Management, , to ensure that a transporter is registered with KDHE. The following questions should be addressed to the facility representative. Are they acting as the final treatment/disposal facility or are they a broker? If they are a broker, how is the actual facility going to treat or dispose of the waste? Who are some of their other customers in your area with similar wastes? Check the company's reputation with their other customers. How will the waste be transported to the facility? Does the company use their own vehicles or a contract carrier? Who is the contract carrier? Obtain a copy of the company's EPA Notification of Regulated Waste Activity (Form ) and copies of portions of permits that cover the kinds of wastes handled at the facility. Does the facility have a minimum charge for their services for each shipment? Is a waste sample required? If so, what fee is assessed for analysis? If you have already had the waste analyzed by an outside laboratory, is that analysis acceptable? Can they use a lab certified by KDHE and assist with a hazardous waste determination? How long will it take to complete arrangements for shipment? Contact the regulatory agency that monitors the facility. Ask to speak with the person most familiar with the site. Most agencies will require a formal information request for open records. Some suggested questions to ask are: Is the facility currently in compliance with all regulations? If not, what are their deficiencies? Is the facility currently under any consent orders for past deficiencies? Has the facility received any fines or penalties in the past? How often is the facility inspected? Is the facility listed on the EPA National Priorities List (NPL) (Superfund cleanup) list? Is the facility transporter or contract carrier transporter registered as a hazardous waste transporter in Kansas? Obtain a contract with the transporter and/or TSDF for their services. Know where your waste is going, how it is being managed, and the disposition of any residues, ash, and empty drums. 30

33 X. How to Avoid Compliance Problems and Minimize Liability The following recommendations are intended to help ensure compliance with the hazardous waste regulations and to minimize the liability associated with generating hazardous wastes. Minimize the amount of hazardous waste generated. This can be done in several ways including a formal Waste Management System or a simple review of what is used at the facility and a look at alternatives to see if less toxic substitutes can be found. Another waste minimization method is to change to different processes that utilize less product and/or produce less waste. Most waste minimization projects pay for themselves within a couple of years through reduced product purchases and reduced waste disposal costs. Good housekeeping, by removing old, unused products, empty containers, old parts, etc. to create space and reduce potential regulatory issues and complaints. Locate and deal with reputable transportation, treatment, and disposal firms (see Section IX). If a price quote is substantially less than the competition, there is probably a reason why. Have backup transporters and disposal sites selected in case your primary providers have problems. Recognize when you lack the expertise to handle a particular problem and seek help from a person with experience in hazardous waste management. These consultants can generally be found in the yellow pages or through a quick internet search. Check listings in the nearest metropolitan areas. If selecting someone from out of state, make sure they have properly registered with KDHE, as applicable. Follow up on all hazardous waste shipments to ensure they reach their intended destination and are treated or disposed. Do not mix hazardous wastes with nonhazardous wastes unless you are familiar with all regulations that may apply. The resultant mixture will be a hazardous waste and may be more difficult or costly to dispose than the original waste. Maintain all records regarding the hazardous waste program (test results, contingency plan, manifests, exception reports, annual reports, training documents) in one location. Designate at least one employee with an appropriate background to be responsible for hazardous waste management. Give that employee the authority and resources to do the job, and then hold him or her accountable. Conduct inspections of your facility and its operations. Do so with an open mind and no preconceived notions of the way things ought to be. 31

34 XI. Resources Available to Assist in Properly Managing Hazardous Waste Kansas Department of Health and Environment (KDHE) The KDHE Bureau of Waste Management (BWM) in Topeka is the primary source of regulatory information and interpretations. BWM staff can be contacted by calling (785) or by writing to: Bureau of Waste Management Curtis State Office Building 1000 SW Jackson, Suite 320 Topeka, KS KDHE also offers assistance through our six district offices where we have available staff that are experts on the Kansas hazardous waste program. The KDHE BWM website, found on the cover of this document offers a wide range of information, including the location and phone numbers for our district offices, Topeka staff phone numbers and addresses, electronic copies of all regulations, policies, technical guidance documents, helpful handouts (including the Hazardous Waste Generator Handbook), and many other resources. Also available on our website is information regarding past and future training, including copies of slides used in those trainings. KDHE s Training/Compliance Manual for RCRA is located in Attachment 6. This manual is designed to help small companies develop an Environmental Management Program (EMP), minimize their hazardous waste, and remain in compliance with the hazardous waste regulations. U.S. Environmental Protection Agency (EPA) EPA provides information on the federal hazardous waste regulations to interested parties. If you have questions, please visit one of EPA s websites. Also, EPA staffs a regional office in Kansas City, Kansas (EPA Region VII). The Region VII office maintains a library of current regulations, guidance documents, and training manuals. Many of these materials are available to the public at no cost through the internet. The telephone number for the Region VII Information Resources Center is (913) Kansas Small Business Environmental Assistance Program (SBEAP) The Small Business Environmental Assistance Program (SBEAP) provides guidance in compliance and technical matters to facilities that otherwise would not have access to such help because of financial constraints. SBEAP emphasizes assistance designed to diminish the burden of compliance and the SBEAP staff will work with you to implement pollution prevention practices such as material substitution, process optimization, waste minimization, and recycling. All services provided by SBEAP are completely confidential, non-regulatory, and free. The SBEAP program is administered by the Pollution Prevention Institute (PPI) at Kansas State University (KSU) for KDHE. Contact PPI at More information may be obtained from the SBEAP website: Other Institutions Other Kansas colleges, universities, and community colleges offer environmental training. For information on any available training, contact the continuing education director at the institution. 32

35 Trade Associations Numerous trade associations exist on local, state, and national levels that represent the interests of individuals or companies who perform a common industrial activity. These associations are generally familiar with the regulations affecting the industry they represent and are able to offer advice and assistance in interpreting the regulations. Some associations also offer training courses, seminars, or conferences focusing on the interpretation and application of regulations. 33

36 ATTACHMENT 1 TOXICITY CHARACTERISTIC CONSTITUENTS REGULATORY LIMITS AND WASTE CODES EPA HW No. 1 Contaminant CAS No. 2 Regulatory Level (mg/l) D004 Arsenic D005 Barium D018 Benzene D006 Cadmium D019 Carbon tetrachloride D020 Chlordane D021 Chlorobenzene D022 Chloroform D007 Chromium D023 o-cresol D024 m-cresol D025 p-cresol D026 Cresol D016 2,4-D D027 1,4-Dichlorobenzene D028 1,2-Dichloroethane D029 1,1-Dichloroethylene D030 2,4-Dinitrotoluene D012 Endrin D031 Heptachlor (and its epoxide) D032 Hexachlorobenzene D033 Hexachlorobutadiene D034 Hexachloroethane D008 Lead D013 Lindane D009 Mercury D014 Methoxychlor D035 Methyl ethyl ketone D036 Nitrobenzene D037 Pentrachlorophenol D038 Pyridine D010 Selenium D011 Silver D039 Tetrachloroethylene D015 Toxaphene D040 Trichloroethylene D041 2,4,5-Trichlorophenol D042 2,4,6-Trichlorophenol

37 D017 2,4,5-TP (Silvex) D043 Vinyl chloride Hazardous waste number. 2 Chemical abstracts service number. 3 Quantitation limit is greater than the calculated regulatory level. The quantitation limit therefore becomes the regulatory level. 4 If o-, m-, and p-cresol concentrations cannot be differentiated, the total cresol (D026) concentration is used. The regulatory level of total cresol is 200 mg/l. [55 FR 11862, Mar. 29, 1990, as amended at 55 FR 22684, June 1, 1990; 55 FR 26987, June 29, 1990; 58 FR 46049, Aug. 31, 1993; 67 FR 11254, Mar. 13, 2002; 71 FR 40259, July 14, 2006] 35

38 ATTACHMENT 2 HAZARDOUS WASTES FROM NON-SPECIFIC SOURCES (F-LIST) 40 CFR Hazardous wastes from non-specific sources. (a) The following solid wastes are listed hazardous wastes from non-specific sources unless they are excluded under 40 CFR and and listed in appendix IX. Industry and EPA hazardous waste No. Generic: Hazardous waste F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures F002 The following spent halogenated solvents: Tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2- trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2- trichloroethane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those listed in F001, F004, or F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures F003 The following spent non-halogenated solvents: Xylene, acetone, ethyl acetate, ethyl (I)* benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends containing, before use, only the above spent non-halogenated solvents; and all spent solvent mixtures/blends containing, before use, one or more of the above non-halogenated solvents, and, a total of ten percent or more (by volume) of one or more of those solvents listed in F001, F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures F004 The following spent non-halogenated solvents: Cresols and cresylic acid, and nitrobenzene; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures F005 The following spent non-halogenated solvents: Toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, or F004; and still bottoms from the recovery of these spent solvents and spent solvent mixtures F006 Wastewater treatment sludges from electroplating operations except from the following processes: (1) Sulfuric acid anodizing of aluminum; (2) tin plating on carbon steel; (3) Hazard code (T) (T) (T) (I,T) (T) 36

39 zinc plating (segregated basis) on carbon steel; (4) aluminum or zinc-aluminum plating on carbon steel; (5) cleaning/stripping associated with tin, zinc and aluminum plating on carbon steel; and (6) chemical etching and milling of aluminum F007 Spent cyanide plating bath solutions from electroplating operations (R, T) F008 Plating bath residues from the bottom of plating baths from electroplating operations where cyanides are used in the process F009 Spent stripping and cleaning bath solutions from electroplating operations where cyanides are used in the process F010 Quenching bath residues from oil baths from metal heat treating operations where cyanides are used in the process (R, T) (R, T) (R, T) F011 Spent cyanide solutions from salt bath pot cleaning from metal heat treating operations (R, T) F012 Quenching waste water treatment sludges from metal heat treating operations where cyanides are used in the process (T) F019 Wastewater treatment sludges from the chemical conversion coating of aluminum (T) except from zirconium phosphating in aluminum can washing when such phosphating is an exclusive conversion coating process. Wastewater treatment sludges from the manufacturing of motor vehicles using a zinc phosphating process will not be subject to this listing at the point of generation if the wastes are not placed outside on the land prior to shipment to a landfill for disposal and are either: disposed in a Subtitle D municipal or industrial landfill unit that is equipped with a single clay liner and is permitted, licensed or otherwise authorized by the state; or disposed in a landfill unit subject to, or otherwise meeting, the landfill requirements in , or For the purposes of this listing, motor vehicle manufacturing is defined in paragraph (b)(4)(i) of this section and (b)(4)(ii) of this section describes the recordkeeping requirements for motor vehicle manufacturing facilities F020 Wastes (except wastewater and spent carbon from hydrogen chloride purification) from the production or manufacturing use (as a reactant, chemical intermediate, or component in a formulating process) of tri- or tetrachlorophenol, or of intermediates used to produce their pesticide derivatives. (This listing does not include wastes from the production of Hexachlorophene from highly purified 2,4,5-trichlorophenol.) F021 Wastes (except wastewater and spent carbon from hydrogen chloride purification) from the production or manufacturing use (as a reactant, chemical intermediate, or component in a formulating process) of pentachlorophenol, or of intermediates used to produce its derivatives F022 Wastes (except wastewater and spent carbon from hydrogen chloride purification) from the manufacturing use (as a reactant, chemical intermediate, or component in a formulating process) of tetra-, penta-, or hexachlorobenzenes under alkaline conditions F023 Wastes (except wastewater and spent carbon from hydrogen chloride purification) from (H) the production of materials on equipment previously used for the production or manufacturing use (as a reactant, chemical intermediate, or component in a formulating process) of tri- and tetrachlorophenols. (This listing does not include wastes from equipment used only for the production or use of Hexachlorophene from highly purified 2,4,5-trichlorophenol.) (H) (H) (H) 37

40 F024 Process wastes, including but not limited to, distillation residues, heavy ends, tars, and reactor clean-out wastes, from the production of certain chlorinated aliphatic hydrocarbons by free radical catalyzed processes. These chlorinated aliphatic hydrocarbons are those having carbon chain lengths ranging from one to and including five, with varying amounts and positions of chlorine substitution. (This listing does not include wastewaters, wastewater treatment sludges, spent catalysts, and wastes listed in or ) F025 Condensed light ends, spent filters and filter aids, and spent desiccant wastes from the production of certain chlorinated aliphatic hydrocarbons, by free radical catalyzed processes. These chlorinated aliphatic hydrocarbons are those having carbon chain lengths ranging from one to and including five, with varying amounts and positions of chlorine substitution (T) (T) F026 Wastes (except wastewater and spent carbon from hydrogen chloride purification) from the production of materials on equipment previously used for the manufacturing use (as a reactant, chemical intermediate, or component in a formulating process) of tetra-, penta-, or hexachlorobenzene under alkaline conditions F027 Discarded unused formulations containing tri-, tetra-, or pentachlorophenol or discarded unused formulations containing compounds derived from these chlorophenols. (This listing does not include formulations containing Hexachlorophene sythesized from prepurified 2,4,5-trichlorophenol as the sole component.) (H) (H) F028 Residues resulting from the incineration or thermal treatment of soil contaminated with EPA Hazardous Waste Nos. F020, F021, F022, F023, F026, and F027 F032 Wastewaters (except those that have not come into contact with process contaminants), process residuals, preservative drippage, and spent formulations from wood preserving processes generated at plants that currently use or have previously used chlorophenolic formulations (except potentially cross-contaminated wastes that have had the F032 waste code deleted in accordance with of this chapter or potentially crosscontaminated wastes that are otherwise currently regulated as hazardous wastes (i.e., F034 or F035), and where the generator does not resume or initiate use of chlorophenolic formulations). This listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote and/or pentachlorophenol F034 Wastewaters (except those that have not come into contact with process contaminants), process residuals, preservative drippage, and spent formulations from wood preserving processes generated at plants that use creosote formulations. This listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote and/or pentachlorophenol F035 Wastewaters (except those that have not come into contact with process contaminants), process residuals, preservative drippage, and spent formulations from wood preserving processes generated at plants that use inorganic preservatives containing arsenic or chromium. This listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote and/or pentachlorophenol F037 Petroleum refinery primary oil/water/solids separation sludge Any sludge generated from the gravitational separation of oil/water/solids during the storage or treatment of (T) (T) (T) (T) (T) 38

41 process wastewaters and oily cooling wastewaters from petroleum refineries. Such sludges include, but are not limited to, those generated in oil/water/solids separators; tanks and impoundments; ditches and other conveyances; sumps; and stormwater units receiving dry weather flow. Sludge generated in stormwater units that do not receive dry weather flow, sludges generated from non-contact once-through cooling waters segregated for treatment from other process or oily cooling waters, sludges generated in aggressive biological treatment units as defined in (b)(2) (including sludges generated in one or more additional units after wastewaters have been treated in aggressive biological treatment units) and K051 wastes are not included in this listing. This listing does include residuals generated from processing or recycling oil-bearing hazardous secondary materials excluded under 261.4(a)(12)(i), if those residuals are to be disposed of F038 Petroleum refinery secondary (emulsified) oil/water/solids separation sludge Any (T) sludge and/or float generated from the physical and/or chemical separation of oil/water/solids in process wastewaters and oily cooling wastewaters from petroleum refineries. Such wastes include, but are not limited to, all sludges and floats generated in: induced air flotation (IAF) units, tanks and impoundments, and all sludges generated in DAF units. Sludges generated in stormwater units that do not receive dry weather flow, sludges generated from non-contact once-through cooling waters segregated for treatment from other process or oily cooling waters, sludges and floats generated in aggressive biological treatment units as defined in (b)(2) (including sludges and floats generated in one or more additional units after wastewaters have been treated in aggressive biological treatment units) and F037, K048, and K051 wastes are not included in this listing F039 Leachate (liquids that have percolated through land disposed wastes) resulting from the disposal of more than one restricted waste classified as hazardous under subpart D of this part. (Leachate resulting from the disposal of one or more of the following EPA Hazardous Wastes and no other Hazardous Wastes retains its EPA Hazardous Waste Number(s): F020, F021, F022, F026, F027, and/or F028.) (T) *(I,T) should be used to specify mixtures that are ignitable and contain toxic constituents. [46 FR 4617, Jan. 16, 1981] 39

42 ATTACHMENT 3 HAZARDOUS WASTES FROM SPECIFIC SOURCES (K-LIST) 40 CFR Hazardous wastes from specific sources. (a)the following solid wastes are listed hazardous wastes from specific sources unless they are excluded under 40 CFR and and listed in appendix IX. Industry and EPA hazardous waste No. Wood preservation: K001 Inorganic pigments: K002 Hazardous waste Bottom sediment sludge from the treatment of wastewaters from wood preserving processes that use creosote and/or pentachlorophenol Hazard code Wastewater treatment sludge from the production of chrome yellow and (T) orange pigments K003 Wastewater treatment sludge from the production of molybdate orange (T) pigments K004 Wastewater treatment sludge from the production of zinc yellow pigments (T) K005 Wastewater treatment sludge from the production of chrome green (T) pigments K006 Wastewater treatment sludge from the production of chrome oxide green (T) pigments (anhydrous and hydrated) K007 Wastewater treatment sludge from the production of iron blue pigments (T) K008 Oven residue from the production of chrome oxide green pigments (T) Organic chemicals: K009 Distillation bottoms from the production of acetaldehyde from ethylene (T) K010 Distillation side cuts from the production of acetaldehyde from ethylene (T) K011 Bottom stream from the wastewater stripper in the production of (R, T) acrylonitrile K013 Bottom stream from the acetonitrile column in the production of (R, T) acrylonitrile K014 Bottoms from the acetonitrile purification column in the production of (T) acrylonitrile K015 Still bottoms from the distillation of benzyl chloride (T) K016 Heavy ends or distillation residues from the production of carbon (T) tetrachloride K017 Heavy ends (still bottoms) from the purification column in the production (T) of epichlorohydrin K018 Heavy ends from the fractionation column in ethyl chloride production (T) K019 Heavy ends from the distillation of ethylene dichloride in ethylene (T) dichloride production K020 Heavy ends from the distillation of vinyl chloride in vinyl chloride (T) monomer production K021 Aqueous spent antimony catalyst waste from fluoromethanes production (T) K022 Distillation bottom tars from the production of phenol/acetone from cumene (T) (T) 40

43 K023 Distillation light ends from the production of phthalic anhydride from (T) naphthalene K024 Distillation bottoms from the production of phthalic anhydride from (T) naphthalene K025 Distillation bottoms from the production of nitrobenzene by the nitration of (T) benzene K026 Stripping still tails from the production of methy ethyl pyridines (T) K027 Centrifuge and distillation residues from toluene diisocyanate production (R, T) K028 Spent catalyst from the hydrochlorinator reactor in the production of 1,1,1- (T) trichloroethane K029 Waste from the product steam stripper in the production of 1,1,1- (T) trichloroethane K030 Column bottoms or heavy ends from the combined production of (T) trichloroethylene and perchloroethylene K083 Distillation bottoms from aniline production (T) K085 Distillation or fractionation column bottoms from the production of (T) chlorobenzenes K093 Distillation light ends from the production of phthalic anhydride from (T) ortho-xylene K094 Distillation bottoms from the production of phthalic anhydride from orthoxylene (T) K095 Distillation bottoms from the production of 1,1,1-trichloroethane (T) K096 Heavy ends from the heavy ends column from the production of 1,1,1- (T) trichloroethane K103 Process residues from aniline extraction from the production of aniline (T) K104 Combined wastewater streams generated from nitrobenzene/aniline (T) production K105 Separated aqueous stream from the reactor product washing step in the (T) production of chlorobenzenes K107 Column bottoms from product separation from the production of 1,1- (C,T) dimethylhydrazine (UDMH) from carboxylic acid hydrazines K108 Condensed column overheads from product separation and condensed (I,T) reactor vent gases from the production of 1,1-dimethylhydrazine (UDMH) from carboxylic acid hydrazides K109 Spent filter cartridges from product purification from the production of 1,1- (T) dimethylhydrazine (UDMH) from carboxylic acid hydrazides K110 Condensed column overheads from intermediate separation from the (T) production of 1,1-dimethylhydrazine (UDMH) from carboxylic acid hydrazides K111 Product washwaters from the production of dinitrotoluene via nitration of (C,T) toluene K112 Reaction by-product water from the drying column in the production of (T) toluenediamine via hydrogenation of dinitrotoluene K113 Condensed liquid light ends from the purification of toluenediamine in the (T) production of toluenediamine via hydrogenation of dinitrotoluene K114 Vicinals from the purification of toluenediamine in the production of (T) 41

44 toluenediamine via hydrogenation of dinitrotoluene K115 Heavy ends from the purification of toluenediamine in the production of (T) toluenediamine via hydrogenation of dinitrotoluene K116 Organic condensate from the solvent recovery column in the production of (T) toluene diisocyanate via phosgenation of toluenediamine K117 Wastewater from the reactor vent gas scrubber in the production of ethylene (T) dibromide via bromination of ethene K118 Spent adsorbent solids from purification of ethylene dibromide in the (T) production of ethylene dibromide via bromination of ethene K136 Still bottoms from the purification of ethylene dibromide in the production (T) of ethylene dibromide via bromination of ethene K149 Distillation bottoms from the production of alpha- (or methyl-) chlorinated (T) toluenes, ring-chlorinated toluenes, benzoyl chlorides, and compounds with mixtures of these functional groups, (This waste does not include still bottoms from the distillation of benzyl chloride.) K150 Organic residuals, excluding spent carbon adsorbent, from the spent (T) chlorine gas and hydrochloric acid recovery processes associated with the production of alpha- (or methyl-) chlorinated toluenes, ring-chlorinated toluenes, benzoyl chlorides, and compounds with mixtures of these functional groups K151 Wastewater treatment sludges, excluding neutralization and biological (T) sludges, generated during the treatment of wastewaters from the production of alpha- (or methyl-) chlorinated toluenes, ring-chlorinated toluenes, benzoyl chlorides, and compounds with mixtures of these functional groups K156 Organic waste (including heavy ends, still bottoms, light ends, spent (T) solvents, filtrates, and decantates) from the production of carbamates and carbamoyl oximes. (This listing does not apply to wastes generated from the manufacture of 3-iodo-2-propynyl n-butylcarbamate.) K157 Wastewaters (including scrubber waters, condenser waters, washwaters, (T) and separation waters) from the production of carbamates and carbamoyl oximes. (This listing does not apply to wastes generated from the manufacture of 3-iodo-2-propynyl n-butylcarbamate.) K158 Bag house dusts and filter/separation solids from the production of (T) carbamates and carbamoyl oximes. (This listing does not apply to wastes generated from the manufacture of 3-iodo-2-propynyl n-butylcarbamate.) K159 Organics from the treatment of thiocarbamate wastes (T) K161 Purification solids (including filtration, evaporation, and centrifugation (R,T) solids), bag house dust and floor sweepings from the production of dithiocarbamate acids and their salts. (This listing does not include K125 or K126.) K174 Wastewater treatment sludges from the production of ethylene dichloride or vinyl chloride monomer (including sludges that result from commingled ethylene dichloride or vinyl chloride monomer wastewater and other wastewater), unless the sludges meet the following conditions: (i) they are disposed of in a subtitle C or non-hazardous landfill licensed or permitted by the state or federal government; (ii) they are not otherwise placed on the land prior to final disposal; and (iii) the generator maintains documentation demonstrating that the waste was either disposed of in an on-site landfill or (T) 42

45 K175 K181 Inorganic chemicals: K071 K073 K106 K176 K177 K178 Pesticides: consigned to a transporter or disposal facility that provided a written commitment to dispose of the waste in an off-site landfill. Respondents in any action brought to enforce the requirements of subtitle C must, upon a showing by the government that the respondent managed wastewater treatment sludges from the production of vinyl chloride monomer or ethylene dichloride, demonstrate that they meet the terms of the exclusion set forth above. In doing so, they must provide appropriate documentation (e.g., contracts between the generator and the landfill owner/operator, invoices documenting delivery of waste to landfill, etc.) that the terms of the exclusion were met Wastewater treatment sludges from the production of vinyl chloride monomer using mercuric chloride catalyst in an acetylene-based process Nonwastewaters from the production of dyes and/or pigments (including nonwastewaters commingled at the point of generation with nonwastewaters from other processes) that, at the point of generation, contain mass loadings of any of the constituents identified in paragraph (c) of this section that are equal to or greater than the corresponding paragraph (c) levels, as determined on a calendar year basis. These wastes will not be hazardous if the nonwastewaters are: (i) disposed in a Subtitle D landfill unit subject to the design criteria in , (ii) disposed in a Subtitle C landfill unit subject to either or , (iii) disposed in other Subtitle D landfill units that meet the design criteria in , , or , or (iv) treated in a combustion unit that is permitted under Subtitle C, or an onsite combustion unit that is permitted under the Clean Air Act. For the purposes of this listing, dyes and/or pigments production is defined in paragraph (b)(1) of this section. Paragraph (d) of this section describes the process for demonstrating that a facility's nonwastewaters are not K181. This listing does not apply to wastes that are otherwise identified as hazardous under and at the point of generation. Also, the listing does not apply to wastes generated before any annual mass loading limit is met Brine purification muds from the mercury cell process in chlorine production, where separately prepurified brine is not used Chlorinated hydrocarbon waste from the purification step of the diaphragm cell process using graphite anodes in chlorine production Wastewater treatment sludge from the mercury cell process in chlorine production Baghouse filters from the production of antimony oxide, including filters from the production of intermediates (e.g., antimony metal or crude antimony oxide) Slag from the production of antimony oxide that is speculatively accumulated or disposed, including slag from the production of intermediates (e.g., antimony metal or crude antimony oxide) Residues from manufacturing and manufacturing-site storage of ferric chloride from acids formed during the production of titanium dioxide using the chloride-ilmenite process (T) (T) (T) (T) (T) (E) (T) (T) 43

46 K031 By-product salts generated in the production of MSMA and cacodylic acid (T) K032 Wastewater treatment sludge from the production of chlordane (T) K033 Wastewater and scrub water from the chlorination of cyclopentadiene in the (T) production of chlordane K034 Filter solids from the filtration of hexachlorocyclopentadiene in the (T) production of chlordane K035 Wastewater treatment sludges generated in the production of creosote (T) K036 Still bottoms from toluene reclamation distillation in the production of (T) disulfoton K037 Wastewater treatment sludges from the production of disulfoton (T) K038 Wastewater from the washing and stripping of phorate production (T) K039 Filter cake from the filtration of diethylphosphorodithioic acid in the (T) production of phorate K040 Wastewater treatment sludge from the production of phorate (T) K041 Wastewater treatment sludge from the production of toxaphene (T) K042 Heavy ends or distillation residues from the distillation of (T) tetrachlorobenzene in the production of 2,4,5-T K043 2,6-Dichlorophenol waste from the production of 2,4-D (T) K097 Vacuum stripper discharge from the chlordane chlorinator in the production (T) of chlordane K098 Untreated process wastewater from the production of toxaphene (T) K099 Untreated wastewater from the production of 2,4-D (T) K123 Process wastewater (including supernates, filtrates, and washwaters) from (T) the production of ethylenebisdithiocarbamic acid and its salt K124 Reactor vent scrubber water from the production of (C, T) ethylenebisdithiocarbamic acid and its salts K125 Filtration, evaporation, and centrifugation solids from the production of (T) ethylenebisdithiocarbamic acid and its salts K126 Baghouse dust and floor sweepings in milling and packaging operations (T) from the production or formulation of ethylenebisdithiocarbamic acid and its salts K131 Wastewater from the reactor and spent sulfuric acid from the acid dryer (C, T) from the production of methyl bromide K132 Spent absorbent and wastewater separator solids from the production of (T) methyl bromide Explosives: K044 Wastewater treatment sludges from the manufacturing and processing of (R) explosives K045 Spent carbon from the treatment of wastewater containing explosives (R) K046 Wastewater treatment sludges from the manufacturing, formulation and (T) loading of lead-based initiating compounds K047 Pink/red water from TNT operations (R) Petroleum refining: K048 Dissolved air flotation (DAF) float from the petroleum refining industry (T) K049 Slop oil emulsion solids from the petroleum refining industry (T) 44

47 K050 Heat exchanger bundle cleaning sludge from the petroleum refining (T) industry K051 API separator sludge from the petroleum refining industry (T) K052 Tank bottoms (leaded) from the petroleum refining industry (T) K169 Crude oil storage tank sediment from petroleum refining operations (T) K170 Clarified slurry oil tank sediment and/or in-line filter/separation solids from (T) petroleum refining operations K171 Spent Hydrotreating catalyst from petroleum refining operations, including (I,T) guard beds used to desulfurize feeds to other catalytic reactors (this listing does not include inert support media) K172 Spent Hydrorefining catalyst from petroleum refining operations, including (I,T) guard beds used to desulfurize feeds to other catalytic reactors (this listing does not include inert support media) Iron and steel: K061 Emission control dust/sludge from the primary production of steel in (T) electric furnaces K062 Spent pickle liquor generated by steel finishing operations of facilities (C,T) within the iron and steel industry (SIC Codes 331 and 332) Primary aluminum: K088 Spent potliners from primary aluminum reduction (T) Secondary lead: K069 Emission control dust/sludge from secondary lead smelting. (Note: This (T) listing is stayed administratively for sludge generated from secondary acid scrubber systems. The stay will remain in effect until further administrative action is taken. If EPA takes further action effecting this stay, EPA will publish a notice of the action in the Federal Register ) K100 Waste leaching solution from acid leaching of emission control dust/sludge (T) from secondary lead smelting Veterinary pharmaceuticals: K084 Wastewater treatment sludges generated during the production of veterinary (T) pharmaceuticals from arsenic or organo-arsenic compounds K101 Distillation tar residues from the distillation of aniline-based compounds in (T) the production of veterinary pharmaceuticals from arsenic or organoarsenic compounds K102 Residue from the use of activated carbon for decolorization in the production of veterinary pharmaceuticals from arsenic or organo-arsenic compounds (T) Ink formulation: K086 Solvent washes and sludges, caustic washes and sludges, or water washes and sludges from cleaning tubs and equipment used in the formulation of ink from pigments, driers, soaps, and stabilizers containing chromium and lead Coking: K060 Ammonia still lime sludge from coking operations (T) K087 Decanter tank tar sludge from coking operations (T) (T) 45

48 K141 Process residues from the recovery of coal tar, including, but not limited to, (T) collecting sump residues from the production of coke from coal or the recovery of coke by-products produced from coal. This listing does not include K087 (decanter tank tar sludges from coking operations) K142 Tar storage tank residues from the production of coke from coal or from the (T) recovery of coke by-products produced from coal K143 Process residues from the recovery of light oil, including, but not limited to, (T) those generated in stills, decanters, and wash oil recovery units from the recovery of coke by-products produced from coal K144 Wastewater sump residues from light oil refining, including, but not limited (T) to, intercepting or contamination sump sludges from the recovery of coke by-products produced from coal K145 Residues from naphthalene collection and recovery operations from the (T) recovery of coke by-products produced from coal K147 Tar storage tank residues from coal tar refining (T) K148 Residues from coal tar distillation, including but not limited to, still bottoms (T) 46

49 ATTACHMENT 4 DISCARDED ACUTELY TOXIC COMMERCIAL CHEMICAL PRODUCTS, OFF- SPECIFICATION SPECIES, CONTAINER RESIDUES AND SPILLS THEREOF (P-LIST) 40 CFR Discarded commercial chemical products, off-specification species, container residues, and spill residues thereof. The following materials or items are hazardous wastes if and when they are discarded or intended to be discarded as described in 261.2(a)(2)(i), when they are mixed with waste oil or used oil or other material and applied to the land for dust suppression or road treatment, when they are otherwise applied to the land in lieu of their original intended use or when they are contained in products that are applied to the land in lieu of their original intended use, or when, in lieu of their original intended use, they are produced for use as (or as a component of) a fuel, distributed for use as a fuel, or burned as a fuel. [ Comment: For the convenience of the regulated community the primary hazardous properties of these materials have been indicated by the letters T (Toxicity), and R (Reactivity). Absence of a letter indicates that the compound only is listed for acute toxicity. Wastes are first listed in alphabetical order by substance and then listed again in numerical order by Hazardous Waste Number.] These wastes and their corresponding EPA Hazardous Waste Numbers are: Haz waste No. P023 P002 P057 P058 P002 P003 P070 P203 P004 P005 P006 P007 P008 P009 P119 P099 Chemical abstracts No. Substance Acetaldehyde, chloro Acetamide, N-(aminothioxomethyl) Acetamide, 2-fluoro Acetic acid, fluoro-, sodium salt Acetyl-2-thiourea Acrolein Aldicarb Aldicarb sulfone Aldrin Allyl alcohol Aluminum phosphide (R,T) (Aminomethyl)-3-isoxazolol Aminopyridine Ammonium picrate (R) Ammonium vanadate Argentate(1-), bis(cyano-c)-, potassium P Arsenic acid H 3 AsO 4 P Arsenic oxide As 2 O 3 P Arsenic oxide As 2 O 5 P Arsenic pentoxide P Arsenic trioxide 47

50 P038 P036 P054 P067 P013 P024 P077 P028 P042 P046 P014 P127 P188 P001 P028 P015 P017 P018 P045 P Arsine, diethyl Arsonous dichloride, phenyl Aziridine Aziridine, 2-methyl Barium cyanide Benzenamine, 4-chloro Benzenamine, 4-nitro Benzene, (chloromethyl) ,2-Benzenediol, 4-[1-hydroxy-2-(methylamino)ethyl]-, (R) Benzeneethanamine, alpha,alpha-dimethyl Benzenethiol Benzofuranol, 2,3-dihydro-2,2-dimethyl-, methylcarbamate Benzoic acid, 2-hydroxy-, compd. with (3aS-cis)-1,2,3,3a,8,8a-hexahydro-1,3a,8- trimethylpyrrolo[2,3-b]indol-5-yl methylcarbamate ester (1:1) H-1-Benzopyran-2-one, 4-hydroxy-3-(3-oxo-1-phenylbutyl)-, & salts, when present at concentrations greater than 0.3% Benzyl chloride Beryllium powder Bromoacetone Brucine Butanone, 3,3-dimethyl-1-(methylthio)-, O-[(methylamino)carbonyl] oxime Calcium cyanide P Calcium cyanide Ca(CN) 2 P Carbamic acid, [(dibutylamino)- thio]methyl-, 2,3-dihydro-2,2-dimethyl- 7- benzofuranyl ester. P Carbamic acid, dimethyl-, 1-[(dimethyl-amino)carbonyl]- 5-methyl-1H- pyrazol-3- yl ester. P Carbamic acid, dimethyl-, 3-methyl-1- (1-methylethyl)-1H- pyrazol-5-yl ester. P Carbamic acid, methyl-, 3-methylphenyl ester. P Carbofuran. P Carbon disulfide P Carbonic dichloride P Carbosulfan. P Chloroacetaldehyde P p-chloroaniline P (o-Chlorophenyl)thiourea P Chloropropionitrile P Copper cyanide P Copper cyanide Cu(CN) P m-cumenyl methylcarbamate. P030 Cyanides (soluble cyanide salts), not otherwise specified P Cyanogen P Cyanogen chloride 48

51 P033 P034 P016 P036 P037 P038 P041 P040 P043 P004 P060 P037 P051 P044 P046 P191 P047 P048 P020 P085 P111 P039 P049 P185 P050 P088 P051 P051 P042 P031 P194 P066 P101 P054 P Cyanogen chloride (CN)Cl Cyclohexyl-4,6-dinitrophenol Dichloromethyl ether Dichlorophenylarsine Dieldrin Diethylarsine Diethyl-p-nitrophenyl phosphate O,O-Diethyl O-pyrazinyl phosphorothioate Diisopropylfluorophosphate (DFP) ,4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexa- chloro-1,4,4a,5,8,8a,- hexahydro-, (1alpha,4alpha,4abeta,5alpha,8alpha,8abeta) ,4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexa- chloro-1,4,4a,5,8,8ahexahydro-, (1alpha,4alpha,4abeta,5beta,8beta,8abeta) ,7:3,6-Dimethanonaphth[2,3-b]oxirene, 3,4,5,6,9,9-hexachloro- 1a,2,2a,3,6,6a,7,7a-octahydro-, (1aalpha,2beta,2aalpha,3beta,6beta,6aalpha,7beta, 7aalpha) ,7:3,6-Dimethanonaphth [2,3-b]oxirene, 3,4,5,6,9,9-hexachloro- 1a,2,2a,3,6,6a,7,7a-octahydro-, (1aalpha,2beta,2abeta,3alpha,6alpha,6abeta,7beta, 7aalpha)-, & metabolites Dimethoate alpha,alpha-dimethylphenethylamine Dimetilan ,6-Dinitro-o-cresol, & salts ,4-Dinitrophenol Dinoseb Diphosphoramide, octamethyl Diphosphoric acid, tetraethyl ester Disulfoton Dithiobiuret ,3-Dithiolane-2-carboxaldehyde, 2,4-dimethyl-, O- [(methylamino)- carbonyl]oxime Endosulfan Endothall Endrin Endrin, & metabolites Epinephrine Ethanedinitrile Ethanimidothioic acid, 2-(dimethylamino)-N-[[(methylamino) carbonyl]oxy]-2- oxo-, methyl ester Ethanimidothioic acid, N-[[(methylamino)carbonyl]oxy]-, methyl ester Ethyl cyanide Ethyleneimine Famphur 49

52 P Fluorine P Fluoroacetamide P Fluoroacetic acid, sodium salt P Formetanate hydrochloride. P Formparanate. P Fulminic acid, mercury(2+) salt (R,T) P Heptachlor P Hexaethyl tetraphosphate P Hydrazinecarbothioamide P Hydrazine, methyl- P Hydrocyanic acid P Hydrogen cyanide P Hydrogen phosphide P Isodrin P Isolan. P Isopropylphenyl N-methylcarbamate. P (2H)-Isoxazolone, 5-(aminomethyl)- P Manganese, bis(dimethylcarbamodithioato-s,s )-, P Manganese dimethyldithiocarbamate. P Mercury, (acetato-o)phenyl- P Mercury fulminate (R,T) P Methanamine, N-methyl-N-nitroso- P Methane, isocyanato- P Methane, oxybis[chloro- P Methane, tetranitro- (R) P Methanethiol, trichloro- P Methanimidamide, N,N-dimethyl-N -[3-[[(methylamino)-carbonyl]oxy]phenyl]-, monohydrochloride. P Methanimidamide, N,N-dimethyl-N -[2-methyl-4- [[(methylamino)carbonyl]oxy]phenyl]- P ,9-Methano-2,4,3-benzodioxathiepin, 6,7,8,9,10,10- hexachloro-1,5,5a,6,9,9a-hexahydro-, 3-oxide P ,7-Methano-1H-indene, 1,4,5,6,7,8,8-heptachloro- 3a,4,7,7a-tetrahydro- P Methiocarb. P Methomyl P Methyl hydrazine P Methyl isocyanate P Methyllactonitrile P Methyl parathion P Metolcarb. P Mexacarbate. P alpha-naphthylthiourea P Nickel carbonyl 50

53 P073 P Nickel carbonyl Ni(CO) 4, (T-4) Nickel cyanide P Nickel cyanide Ni(CN) 2 P Nicotine, & salts P Nitric oxide P p-nitroaniline P Nitrogen dioxide P Nitrogen oxide NO P Nitrogen oxide NO 2 P Nitroglycerine (R) P N-Nitrosodimethylamine P N-Nitrosomethylvinylamine P Octamethylpyrophosphoramide P Osmium oxide OsO 4, (T-4)- P Osmium tetroxide P Oxabicyclo[2.2.1]heptane-2,3-dicarboxylic acid P Oxamyl. P Parathion P Phenol, 2-cyclohexyl-4,6-dinitro- P Phenol, 2,4-dinitro- P Phenol, 2-methyl-4,6-dinitro-, & salts P Phenol, 2-(1-methylpropyl)-4,6-dinitro- P Phenol, 2,4,6-trinitro-, ammonium salt (R) P Phenol, 4-(dimethylamino)-3,5-dimethyl-, methylcarbamate (ester). P Phenol, (3,5-dimethyl-4-(methylthio)-, methylcarbamate P Phenol, 3-(1-methylethyl)-, methyl carbamate. P Phenol, 3-methyl-5-(1-methylethyl)-, methyl carbamate. P Phenylmercury acetate P Phenylthiourea P Phorate P Phosgene P Phosphine P Phosphoric acid, diethyl 4-nitrophenyl ester P Phosphorodithioic acid, O,O-diethyl S-[2-(ethylthio)ethyl] ester P Phosphorodithioic acid, O,O-diethyl S-[(ethylthio)methyl] ester P Phosphorodithioic acid, O,O-dimethyl S-[2-(methylamino)-2-oxoethyl] ester P Phosphorofluoridic acid, bis(1-methylethyl) ester P Phosphorothioic acid, O,O-diethyl O-(4-nitrophenyl) ester P Phosphorothioic acid, O,O-diethyl O-pyrazinyl ester P Phosphorothioic acid, O-[4-[(dimethylamino)sulfonyl]phenyl] O,O-dimethyl ester P Phosphorothioic acid, O,O,-dimethyl O-(4-nitrophenyl) ester 51

54 P204 P188 P110 P098 P098 P099 P201 P070 P203 P101 P027 P069 P081 P017 P102 P003 P005 P067 P102 P008 P075 P204 P114 P103 P104 P104 P105 P106 P106 P108 P018 P108 P115 P109 P110 P111 P112 P062 P Physostigmine Physostigmine salicylate Plumbane, tetraethyl Potassium cyanide Potassium cyanide K(CN) Potassium silver cyanide Promecarb Propanal, 2-methyl-2-(methylthio)-, O-[(methylamino)carbonyl]oxime Propanal, 2-methyl-2-(methyl-sulfonyl)-, O-[(methylamino)carbonyl] oxime Propanenitrile Propanenitrile, 3-chloro Propanenitrile, 2-hydroxy-2-methyl ,2,3-Propanetriol, trinitrate (R) Propanone, 1-bromo Propargyl alcohol Propenal Propen-1-ol ,2-Propylenimine Propyn-1-ol Pyridinamine Pyridine, 3-(1-methyl-2-pyrrolidinyl)-, (S)-, & salts Pyrrolo[2,3-b]indol-5-ol, 1,2,3,3a,8,8a-hexahydro-1,3a,8-trimethyl-, methylcarbamate (ester), (3aS-cis) Selenious acid, dithallium(1+) salt Selenourea Silver cyanide Silver cyanide Ag(CN) Sodium azide Sodium cyanide Sodium cyanide Na(CN) Strychnidin-10-one, & salts Strychnidin-10-one, 2,3-dimethoxy Strychnine, & salts Sulfuric acid, dithallium(1+) salt Tetraethyldithiopyrophosphate Tetraethyl lead Tetraethyl pyrophosphate Tetranitromethane (R) Tetraphosphoric acid, hexaethyl ester Thallic oxide P Thallium oxide Tl 2 O 3 P Thallium(I) selenite 52

55 P115 P109 P045 P049 P014 P116 P026 P072 P093 P185 P123 P118 P Thallium(I) sulfate Thiodiphosphoric acid, tetraethyl ester Thiofanox Thioimidodicarbonic diamide [(H 2 N)C(S)] 2 NH Thiophenol Thiosemicarbazide Thiourea, (2-chlorophenyl) Thiourea, 1-naphthalenyl Thiourea, phenyl Tirpate Toxaphene Trichloromethanethiol Vanadic acid, ammonium salt P Vanadium oxide V 2 O 5 P Vanadium pentoxide P Vinylamine, N-methyl-N-nitroso- P Warfarin, & salts, when present at concentrations greater than 0.3% P Zinc, bis(dimethylcarbamodithioato-s,s )-, P Zinc cyanide P Zinc cyanide Zn(CN) 2 P Zinc phosphide Zn 3 P 2, when present at concentrations greater than 10% (R,T) P Ziram. P H-1-Benzopyran-2-one, 4-hydroxy-3-(3-oxo-1-phenylbutyl)-, & salts, when present at concentrations greater than 0.3% P Warfarin, & salts, when present at concentrations greater than 0.3% P Acetamide, -(aminothioxomethyl)- P Acetyl-2-thiourea P Acrolein P Propenal P Aldrin P ,4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexa-chloro-1,4,4a,5,8,8a,- hexahydro-, (1alpha,4alpha,4abeta,5alpha,8alpha,8abeta)- P Allyl alcohol P Propen-1-ol P Aluminum phosphide (R,T) P (Aminomethyl)-3-isoxazolol P (2H)-Isoxazolone, 5-(aminomethyl)- P Aminopyridine P Pyridinamine P Ammonium picrate (R) P Phenol, 2,4,6-trinitro-, ammonium salt (R) P Arsenic acid H 3 AsO 4 P Arsenic oxide As 2 O 5 53

56 P Arsenic pentoxide P Arsenic oxide As 2 O 3 P Arsenic trioxide P Barium cyanide P Benzenethiol P Thiophenol P Beryllium powder P Dichloromethyl ether P Methane, oxybis[chloro- P Bromoacetone P Propanone, 1-bromo- P Brucine P Strychnidin-10-one, 2,3-dimethoxy- P Dinoseb P Phenol, 2-(1-methylpropyl)-4,6-dinitro- P Calcium cyanide P Calcium cyanide Ca(CN) 2 P Carbon disulfide P Acetaldehyde, chloro- P Chloroacetaldehyde P Benzenamine, 4-chloro- P p-chloroaniline P (o-Chlorophenyl)thiourea P Thiourea, (2-chlorophenyl)- P Chloropropionitrile P Propanenitrile, 3-chloro- P Benzene, (chloromethyl)- P Benzyl chloride P Copper cyanide P Copper cyanide Cu(CN) P030 Cyanides (soluble cyanide salts), not otherwise specified P Cyanogen P Ethanedinitrile P Cyanogen chloride P Cyanogen chloride (CN)Cl P Cyclohexyl-4,6-dinitrophenol P Phenol, 2-cyclohexyl-4,6-dinitro- P Arsonous dichloride, phenyl- P Dichlorophenylarsine P Dieldrin P ,7:3,6-Dimethanonaphth[2,3-b]oxirene, 3,4,5,6,9,9-hexachloro- 1a,2,2a,3,6,6a,7,7a-octahydro-, (1aalpha,2beta,2aalpha,3beta,6beta,6aalpha,7beta, 7aalpha)- 54

57 P038 P038 P039 P039 P040 P040 P041 P041 P042 P042 P043 P043 P044 P044 P045 P045 P046 P046 P047 P047 P048 P048 P049 P049 P050 P050 P051 P051 P051 P054 P054 P056 P057 P057 P058 P058 P059 P059 P060 P Arsine, diethyl Diethylarsine Disulfoton Phosphorodithioic acid, O,O-diethyl S-[2-(ethylthio)ethyl] ester O,O-Diethyl O-pyrazinyl phosphorothioate Phosphorothioic acid, O,O-diethyl O-pyrazinyl ester Diethyl-p-nitrophenyl phosphate Phosphoric acid, diethyl 4-nitrophenyl ester ,2-Benzenediol, 4-[1-hydroxy-2-(methylamino)ethyl]-, (R) Epinephrine Diisopropylfluorophosphate (DFP) Phosphorofluoridic acid, bis(1-methylethyl) ester Dimethoate Phosphorodithioic acid, O,O-dimethyl S-[2-(methyl amino)-2-oxoethyl] ester Butanone, 3,3-dimethyl-1-(methylthio)-, O-[(methylamino)carbonyl] oxime Thiofanox Benzeneethanamine, alpha,alpha-dimethyl alpha,alpha-dimethylphenethylamine ,6-Dinitro-o-cresol, & salts Phenol, 2-methyl-4,6-dinitro-, & salts ,4-Dinitrophenol Phenol, 2,4-dinitro Dithiobiuret Thioimidodicarbonic diamide [(H 2 N)C(S)] 2 NH Endosulfan ,9-Methano-2,4,3-benzodioxathiepin, 6,7,8,9,10,10-hexachloro-1,5,5a,6,9,9ahexahydro-, 3-oxide ,7:3,6-Dimethanonaphth [2,3-b]oxirene, 3,4,5,6,9,9-hexachloro- 1a,2,2a,3,6,6a,7,7a-octahydro-, (1aalpha,2beta,2abeta,3alpha,6alpha,6abeta,7beta, 7aalpha)-, & metabolites Endrin Endrin, & metabolites Aziridine Ethyleneimine Fluorine Acetamide, 2-fluoro Fluoroacetamide Acetic acid, fluoro-, sodium salt Fluoroacetic acid, sodium salt Heptachlor ,7-Methano-1H-indene, 1,4,5,6,7,8,8-heptachloro-3a,4,7,7a-tetrahydro ,4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexa-chloro-1,4,4a,5,8,8ahexahydro-, (1alpha,4alpha,4abeta,5beta,8beta,8abeta) Isodrin 55

58 P062 P062 P063 P063 P064 P064 P065 P065 P066 P066 P067 P067 P068 P068 P069 P069 P070 P070 P071 P071 P072 P072 P073 P073 P Hexaethyl tetraphosphate Tetraphosphoric acid, hexaethyl ester Hydrocyanic acid Hydrogen cyanide Methane, isocyanato Methyl isocyanate Fulminic acid, mercury(2+) salt (R,T) Mercury fulminate (R,T) Ethanimidothioic acid, N-[[(methylamino)carbonyl]oxy]-, methyl ester Methomyl Aziridine, 2-methyl ,2-Propylenimine Hydrazine, methyl Methyl hydrazine Methyllactonitrile Propanenitrile, 2-hydroxy-2-methyl Aldicarb Propanal, 2-methyl-2-(methylthio)-, O-[(methylamino)carbonyl]oxime Methyl parathion Phosphorothioic acid, O,O,-dimethyl O-(4-nitrophenyl) ester alpha-naphthylthiourea Thiourea, 1-naphthalenyl Nickel carbonyl Nickel carbonyl Ni(CO) 4, (T-4) Nickel cyanide P Nickel cyanide Ni(CN) 2 P Nicotine, & salts P Pyridine, 3-(1-methyl-2-pyrrolidinyl)-, (S)-, & salts P Nitric oxide P Nitrogen oxide NO P Benzenamine, 4-nitro- P p-nitroaniline P Nitrogen dioxide P Nitrogen oxide NO 2 P Nitroglycerine (R) P ,2,3-Propanetriol, trinitrate (R) P Methanamine, -methyl-n-nitroso- P N-Nitrosodimethylamine P N-Nitrosomethylvinylamine P Vinylamine, -methyl-n-nitroso- P Diphosphoramide, octamethyl- P Octamethylpyrophosphoramide P Osmium oxide OsO 4, (T-4)- 56

59 P087 P088 P088 P089 P089 P092 P092 P093 P093 P094 P094 P095 P095 P096 P096 P097 P097 P098 P098 P099 P099 P101 P101 P102 P102 P103 P104 P104 P105 P106 P106 P108 P108 P109 P109 P110 P110 P111 P111 P112 P112 P Osmium tetroxide Endothall Oxabicyclo[2.2.1]heptane-2,3-dicarboxylic acid Parathion Phosphorothioic acid, O,O-diethyl O-(4-nitrophenyl) ester Mercury, (acetato-o)phenyl Phenylmercury acetate Phenylthiourea Thiourea, phenyl Phorate Phosphorodithioic acid, O,O-diethyl S-[(ethylthio)methyl] ester Carbonic dichloride Phosgene Hydrogen phosphide Phosphine Famphur Phosphorothioic acid, O-[4-[(dimethylamino)sulfonyl]phenyl] O,O-dimethyl ester Potassium cyanide Potassium cyanide K(CN) Argentate(1-), bis(cyano-c)-, potassium Potassium silver cyanide Ethyl cyanide Propanenitrile Propargyl alcohol Propyn-1-ol Selenourea Silver cyanide Silver cyanide Ag(CN) Sodium azide Sodium cyanide Sodium cyanide Na(CN) Strychnidin-10-one, & salts Strychnine, & salts Tetraethyldithiopyrophosphate Thiodiphosphoric acid, tetraethyl ester Plumbane, tetraethyl Tetraethyl lead Diphosphoric acid, tetraethyl ester Tetraethyl pyrophosphate Methane, tetranitro-(r) Tetranitromethane (R) Thallic oxide P Thallium oxide Tl 2 O 3 57

60 P114 P114 P115 P115 P116 P116 P118 P118 P119 P Selenious acid, dithallium(1+) salt Tetraethyldithiopyrophosphate Thiodiphosphoric acid, tetraethyl ester Plumbane, tetraethyl Tetraethyl lead Thiosemicarbazide Methanethiol, trichloro Trichloromethanethiol Ammonium vanadate Vanadic acid, ammonium salt P Vanadium oxide V 2 O 5 P Vanadium pentoxide P Zinc cyanide P Zinc cyanide Zn(CN) 2 P Zinc phosphide Zn 3 P 2, when present at concentrations greater than 10% (R,T) P Toxaphene P Benzofuranol, 2,3-dihydro-2,2-dimethyl-, methylcarbamate. P Carbofuran P Mexacarbate P Phenol, 4-(dimethylamino)-3,5-dimethyl-, methylcarbamate (ester) P ,3-Dithiolane-2-carboxaldehyde, 2,4-dimethyl-, O-[(methylamino)- carbonyl]oxime. P Tirpate P Benzoic acid, 2-hydroxy-, compd. with (3aS-cis)-1,2,3,3a,8,8a-hexahydro-1,3a,8- trimethylpyrrolo[2,3-b]indol-5-yl methylcarbamate ester (1:1) P Physostigmine salicylate P Carbamic acid, [(dibutylamino)-thio]methyl-, 2,3-dihydro-2,2-dimethyl-7- benzofuranyl ester P Carbosulfan P Carbamic acid, methyl-, 3-methylphenyl ester P Metolcarb P Carbamic acid, dimethyl-, 1-[(dimethyl-amino)carbonyl]-5-methyl-1H-pyrazol-3- yl ester P Dimetilan P Carbamic acid, dimethyl-, 3-methyl-1-(1-methylethyl)-1H-pyrazol-5-yl ester P Isolan P Ethanimidthioic acid, 2-(dimethylamino)-N-[[(methylamino) carbonyl]oxy]-2-oxo-, methyl ester P Oxamyl P Manganese, bis(dimethylcarbamodithioato-s,s')-, P Manganese dimethyldithiocarbamate P Formparanate P Methanimidamide, N,N-dimethyl-N'-[2-methyl-4- [[(methylamino)carbonyl]oxy]phenyl]- 58

61 P198 P198 P199 P199 P201 P201 P202 P202 P202 P203 P203 P204 P204 P205 P Formetanate hydrochloride Methanimidamide, N,N-dimethyl-N'-[3-[[(methylamino)-carbonyl]oxy]phenyl]- monohydrochloride Methiocarb Phenol, (3,5-dimethyl-4-(methylthio)-, methylcarbamate Phenol, 3-methyl-5-(1-methylethyl)-, methyl carbamate Promecarb m-cumenyl methylcarbamate Isopropylphenyl N-methylcarbamate Phenol, 3-(1-methylethyl)-, methyl carbamate Aldicarb sulfone Propanal, 2-methyl-2-(methyl-sulfonyl)-, O-[(methylamino)carbonyl] oxime Physostigmine Pyrrolo[2,3-b]indol-5-ol, 1,2,3,3a,8,8a-hexahydro-1,3a,8-trimethyl-, methylcarbamate (ester), (3aS-cis) Zinc, bis(dimethylcarbamodithioato-s,s')-, Ziram 1 CAS Number given for parent compound only. [Comment: For the convenience of the regulated community, the primary hazardous properties of these materials have been indicated by the letters T (Toxicity), R (Reactivity), I (Ignitability) and C (Corrosivity). Absence of a letter indicates that the compound is only listed for toxicity. Wastes are first listed in alphabetical order by substance and then listed [45 FR 78529, 78541, Nov. 25, 1980] 59

62 ATTACHMENT 5 DISCARDED COMMERCIAL CHEMICAL PRODUCTS, OFF-SPECIFICATION SPECIES, CONTAINER RESIDUES AND SPILLS THEREOF (U-LIST) 40 CFR Discarded commercial chemical products, off-specification species, container residues, and spill residues thereof. The following materials or items are hazardous wastes if and when they are discarded or intended to be discarded as described in 261.2(a)(2)(i), when they are mixed with waste oil or used oil or other material and applied to the land for dust suppression or road treatment, when they are otherwise applied to the land in lieu of their original intended use or when they are contained in products that are applied to the land in lieu of their original intended use, or when, in lieu of their original intended use, they are produced for use as (or as a component of) a fuel, distributed for use as a fuel, or burned as a fuel. [Comment: For the convenience of the regulated community the primary hazardous properties of these materials have been indicated by the letters T (Toxicity), and R (Reactivity). Absence of a letter indicates that the compound only is listed for acute toxicity. Wastes are first listed in alphabetical order by substance and then listed again in numerical order by Hazardous Waste Number.] These wastes and their corresponding EPA Hazardous Waste Numbers are: Hazardous waste No. Chemical abstracts No. Substance U A2213. U Acetaldehyde (I) U Acetaldehyde, trichloro- U Acetamide, N-(4-ethoxyphenyl)- U Acetamide, N-9H-fluoren-2-yl- U Acetic acid, (2,4-dichlorophenoxy)-, salts & esters U Acetic acid ethyl ester (I) U Acetic acid, lead(2+) salt U Acetic acid, thallium(1+) salt see F Acetic acid, (2,4,5-trichlorophenoxy)- U Acetone (I) U Acetonitrile (I,T) U Acetophenone U Acetylaminofluorene U Acetyl chloride (C,R,T) U Acrylamide U Acrylic acid (I) U Acrylonitrile U Amitrole U Aniline (I,T) U Arsinic acid, dimethyl- U Auramine 60

63 U015 U010 U280 U278 U364 U271 U157 U016 U017 U192 U018 U094 U012 U014 U049 U093 U328 U353 U158 U222 U181 U019 U038 U030 U035 U037 U221 U028 U069 U088 U102 U107 U070 U071 U072 U060 U017 U223 U239 U201 U Azaserine Azirino[2,3 :3,4]pyrrolo[1,2-a]indole-4,7-dione, 6-amino-8- [[(aminocarbonyl)oxy]methyl]-1,1a,2,8,8a,8b-hexahydro-8a-methoxy-5- methyl-, [1aS-(1aalpha, 8beta,8aalpha,8balpha)] Barban Bendiocarb Bendiocarb phenol Benomyl Benz[j]aceanthrylene, 1,2-dihydro-3-methyl Benz[c]acridine Benzal chloride Benzamide, 3,5-dichloro-N-(1,1-dimethyl-2-propynyl) Benz[a]anthracene Benz[a]anthracene, 7,12-dimethyl Benzenamine (I,T) Benzenamine, 4,4 -carbonimidoylbis[n,n-dimethyl Benzenamine, 4-chloro-2-methyl-, hydrochloride Benzenamine, N,N-dimethyl-4-(phenylazo) Benzenamine, 2-methyl Benzenamine, 4-methyl Benzenamine, 4,4 -methylenebis[2-chloro Benzenamine, 2-methyl-, hydrochloride Benzenamine, 2-methyl-5-nitro Benzene (I,T) Benzeneacetic acid, 4-chloro-alpha-(4-chlorophenyl)-alpha-hydroxy-, ethyl ester Benzene, 1-bromo-4-phenoxy Benzenebutanoic acid, 4-[bis(2-chloroethyl)amino] Benzene, chloro Benzenediamine, ar-methyl ,2-Benzenedicarboxylic acid, bis(2-ethylhexyl) ester ,2-Benzenedicarboxylic acid, dibutyl ester ,2-Benzenedicarboxylic acid, diethyl ester ,2-Benzenedicarboxylic acid, dimethyl ester ,2-Benzenedicarboxylic acid, dioctyl ester Benzene, 1,2-dichloro Benzene, 1,3-dichloro Benzene, 1,4-dichloro Benzene, 1,1 -(2,2-dichloroethylidene)bis[4-chloro Benzene, (dichloromethyl) Benzene, 1,3-diisocyanatomethyl- (R,T) Benzene, dimethyl- (I) ,3-Benzenediol Benzene, hexachloro- 61

64 U056 U220 U105 U106 U055 U169 U183 U185 U020 U020 U207 U061 U247 U023 U234 U021 U278 U364 U203 U141 U367 U090 U064 U248 U022 U197 U023 U085 U021 U073 U091 U095 U225 U030 U128 U172 U031 U159 U160 U053 U074 U Benzene, hexahydro- (I) Benzene, methyl Benzene, 1-methyl-2,4-dinitro Benzene, 2-methyl-1,3-dinitro Benzene, (1-methylethyl)- (I) Benzene, nitro Benzene, pentachloro Benzene, pentachloronitro Benzenesulfonic acid chloride (C,R) Benzenesulfonyl chloride (C,R) Benzene, 1,2,4,5-tetrachloro Benzene, 1,1 -(2,2,2-trichloroethylidene)bis[4-chloro Benzene, 1,1 -(2,2,2-trichloroethylidene)bis[4- methoxy Benzene, (trichloromethyl) Benzene, 1,3,5-trinitro Benzidine ,3-Benzodioxol-4-ol, 2,2-dimethyl-, methyl carbamate ,3-Benzodioxol-4-ol, 2,2-dimethyl-, ,3-Benzodioxole, 5-(2-propenyl) ,3-Benzodioxole, 5-(1-propenyl) Benzofuranol, 2,3-dihydro-2,2-dimethyl ,3-Benzodioxole, 5-propyl Benzo[rst]pentaphene H-1-Benzopyran-2-one, 4-hydroxy-3-(3-oxo-1-phenyl-butyl)-, & salts, when present at concentrations of 0.3% or less Benzo[a]pyrene p-benzoquinone Benzotrichloride (C,R,T) ,2 -Bioxirane [1,1 -Biphenyl]-4,4 -diamine [1,1 -Biphenyl]-4,4 -diamine, 3,3 -dichloro [1,1 -Biphenyl]-4,4 -diamine, 3,3 -dimethoxy [1,1 -Biphenyl]-4,4 -diamine, 3,3 -dimethyl Bromoform Bromophenyl phenyl ether ,3-Butadiene, 1,1,2,3,4,4-hexachloro Butanamine, N-butyl-N-nitroso Butanol (I) Butanone (I,T) Butanone, peroxide (R,T) Butenal Butene, 1,4-dichloro- (I,T) Butenoic acid, 2-methyl-, 7-[[2,3-dihydroxy- 62

65 U031 U136 U032 U372 U271 U280 U238 U178 U373 U409 U097 U389 U387 U114 U062 U279 U372 U367 U215 U033 U156 U033 U211 U034 U035 U036 U026 U037 U038 U039 U042 U044 U046 U047 U048 U049 U032 U050 2-(1-methoxyethyl)-3-methyl-1-oxobutoxy]methyl]- 2,3,5,7a-tetrahydro-1H-pyrrolizin-1-yl ester, [1S-[1alpha(Z),7(2S*,3R*),7aalpha]] n-butyl alcohol (I) Cacodylic acid Calcium chromate Carbamic acid, 1H-benzimidazol-2-yl, methyl ester Carbamic acid, [1-[(butylamino)carbonyl]-1H-benzimidazol-2-yl]-, methyl ester Carbamic acid, (3-chlorophenyl)-, 4-chloro-2-butynyl ester Carbamic acid, ethyl ester Carbamic acid, methylnitroso-, ethyl ester Carbamic acid, phenyl-, 1-methylethyl ester Carbamic acid, [1,2-phenylenebis (iminocarbonothioyl)]bis-, dimethyl ester Carbamic chloride, dimethyl Carbamothioic acid, bis(1-methylethyl)-, S-(2,3,3-trichloro-2-propenyl) ester Carbamothioic acid, dipropyl-, S-(phenylmethyl) ester Carbamodithioic acid, 1,2-ethanediylbis-, salts & esters Carbamothioic acid, bis(1-methylethyl)-, S-(2,3-dichloro-2-propenyl) ester Carbaryl Carbendazim Carbofuran phenol Carbonic acid, dithallium(1+) salt Carbonic difluoride Carbonochloridic acid, methyl ester (I,T) Carbon oxyfluoride (R,T) Carbon tetrachloride Chloral Chlorambucil Chlordane, alpha & gamma isomers Chlornaphazin Chlorobenzene Chlorobenzilate p-chloro-m-cresol Chloroethyl vinyl ether Chloroform Chloromethyl methyl ether beta-chloronaphthalene o-chlorophenol Chloro-o-toluidine, hydrochloride Chromic acid H 2 CrO 4, calcium salt Chrysene 63

66 U051 U052 U053 U055 U246 U197 U056 U129 U057 U130 U058 U240 U059 U060 U061 U062 U063 U064 U066 U069 U070 U071 U072 U073 U074 U075 U078 U079 U025 U027 U024 U081 U082 U084 U085 U108 U028 U395 U086 U087 U088 U089 Creosote Cresol (Cresylic acid) Crotonaldehyde Cumene (I) Cyanogen bromide (CN)Br ,5-Cyclohexadiene-1,4-dione Cyclohexane (I) Cyclohexane, 1,2,3,4,5,6-hexachloro-, (1alpha,2alpha,3beta,4alpha,5alpha,6beta) Cyclohexanone (I) ,3-Cyclopentadiene, 1,2,3,4,5,5-hexachloro Cyclophosphamide ,4-D, salts & esters Daunomycin DDD DDT Diallate Dibenz[a,h]anthracene Dibenzo[a,i]pyrene ,2-Dibromo-3-chloropropane Dibutyl phthalate o-dichlorobenzene m-dichlorobenzene p-dichlorobenzene ,3 -Dichlorobenzidine ,4-Dichloro-2-butene (I,T) Dichlorodifluoromethane ,1-Dichloroethylene ,2-Dichloroethylene Dichloroethyl ether Dichloroisopropyl ether Dichloromethoxy ethane ,4-Dichlorophenol ,6-Dichlorophenol ,3-Dichloropropene ,2:3,4-Diepoxybutane (I,T) ,4-Diethyleneoxide Diethylhexyl phthalate Diethylene glycol, dicarbamate N,N -Diethylhydrazine O,O-Diethyl S-methyl dithiophosphate Diethyl phthalate Diethylstilbesterol 64

67 U090 U091 U092 U093 U094 U095 U096 U097 U098 U099 U101 U102 U103 U105 U106 U107 U108 U109 U110 U111 U041 U001 U404 U174 U155 U067 U076 U077 U131 U024 U117 U025 U184 U208 U209 U218 U226 U227 U410 U394 U359 U Dihydrosafrole ,3 -Dimethoxybenzidine Dimethylamine (I) p-dimethylaminoazobenzene ,12-Dimethylbenz[a]anthracene ,3 -Dimethylbenzidine alpha,alpha-dimethylbenzylhydroperoxide (R) Dimethylcarbamoyl chloride ,1-Dimethylhydrazine ,2-Dimethylhydrazine ,4-Dimethylphenol Dimethyl phthalate Dimethyl sulfate ,4-Dinitrotoluene ,6-Dinitrotoluene Di-n-octyl phthalate ,4-Dioxane ,2-Diphenylhydrazine Dipropylamine (I) Di-n-propylnitrosamine Epichlorohydrin Ethanal (I) Ethanamine, N,N-diethyl Ethanamine, N-ethyl-N-nitroso ,2-Ethanediamine, N,N-dimethyl-N -2-pyridinyl-N -(2-thienylmethyl) Ethane, 1,2-dibromo Ethane, 1,1-dichloro Ethane, 1,2-dichloro Ethane, hexachloro Ethane, 1,1 -[methylenebis(oxy)]bis[2-chloro Ethane, 1,1 -oxybis-(i) Ethane, 1,1 -oxybis[2-chloro Ethane, pentachloro Ethane, 1,1,1,2-tetrachloro Ethane, 1,1,2,2-tetrachloro Ethanethioamide Ethane, 1,1,1-trichloro Ethane, 1,1,2-trichloro Ethanimidothioic acid, N,N - [thiobis[(methylimino)carbonyloxy]]bis-, dimethyl ester Ethanimidothioic acid, 2-(dimethylamino)-N-hydroxy-2-oxo-, methyl ester Ethanol, 2-ethoxy Ethanol, 2,2 -(nitrosoimino)bis- 65

68 U Ethanol, 2,2 -oxybis-, dicarbamate. U Ethanone, 1-phenyl- U Ethene, chloro- U Ethene, (2-chloroethoxy)- U Ethene, 1,1-dichloro- U Ethene, 1,2-dichloro-, (E)- U Ethene, tetrachloro- U Ethene, trichloro- U Ethyl acetate (I) U Ethyl acrylate (I) U Ethyl carbamate (urethane) U Ethyl ether (I) U Ethylenebisdithiocarbamic acid, salts & esters U Ethylene dibromide U Ethylene dichloride U Ethylene glycol monoethyl ether U Ethylene oxide (I,T) U Ethylenethiourea U Ethylidene dichloride U Ethyl methacrylate U Ethyl methanesulfonate U Fluoranthene U Formaldehyde U Formic acid (C,T) U Furan (I) U Furancarboxaldehyde (I) U ,5-Furandione U Furan, tetrahydro-(i) U Furfural (I) U Furfuran (I) U Glucopyranose, 2-deoxy-2-(3-methyl-3-nitrosoureido)-, D- U D-Glucose, 2-deoxy-2-[[(methylnitrosoamino)- carbonyl]amino]- U Glycidylaldehyde U Guanidine, N-methyl-N -nitro-n-nitroso- U Hexachlorobenzene U Hexachlorobutadiene U Hexachlorocyclopentadiene U Hexachloroethane U Hexachlorophene U Hexachloropropene U Hydrazine (R,T) U Hydrazine, 1,2-diethyl- 66

69 U Hydrazine, 1,1-dimethyl- U Hydrazine, 1,2-dimethyl- U Hydrazine, 1,2-diphenyl- U Hydrofluoric acid (C,T) U Hydrogen fluoride (C,T) U Hydrogen sulfide U Hydrogen sulfide H 2 S U Hydroperoxide, 1-methyl-1-phenylethyl- (R) U Imidazolidinethione U Indeno[1,2,3-cd]pyrene U ,3-Isobenzofurandione U Isobutyl alcohol (I,T) U Isosafrole U Kepone U Lasiocarpine U Lead acetate U Lead, bis(acetato-o)tetrahydroxytri- U Lead phosphate U Lead subacetate U Lindane U MNNG U Maleic anhydride U Maleic hydrazide U Malononitrile U Melphalan U Mercury U Methacrylonitrile (I, T) U Methanamine, N-methyl- (I) U Methane, bromo- U Methane, chloro- (I, T) U Methane, chloromethoxy- U Methane, dibromo- U Methane, dichloro- U Methane, dichlorodifluoro- U Methane, iodo- U Methanesulfonic acid, ethyl ester U Methane, tetrachloro- U Methanethiol (I, T) U Methane, tribromo- U Methane, trichloro- U Methane, trichlorofluoro- U ,7-Methano-1H-indene, 1,2,4,5,6,7,8,8-octachloro-2,3,3a,4,7,7a- hexahydro- 67

70 U Methanol (I) U Methapyrilene U ,3,4-Metheno-2H-cyclobuta[cd]pentalen-2-one, 1,1a,3,3a,4,5,5,5a,5b,6- decachlorooctahydro- U Methoxychlor U Methyl alcohol (I) U Methyl bromide U Methylbutadiene (I) U Methyl chloride (I,T) U Methyl chlorocarbonate (I,T) U Methyl chloroform U Methylcholanthrene U ,4 -Methylenebis(2-chloroaniline) U Methylene bromide U Methylene chloride U Methyl ethyl ketone (MEK) (I,T) U Methyl ethyl ketone peroxide (R,T) U Methyl iodide U Methyl isobutyl ketone (I) U Methyl methacrylate (I,T) U Methyl-2-pentanone (I) U Methylthiouracil U Mitomycin C U ,12-Naphthacenedione, 8-acetyl-10-[(3-amino-2,3,6-trideoxy)-alpha-L- lyxo-hexopyranosyl)oxy]-7,8,9,10-tetrahydro-6,8,11-trihydroxy-1-methoxy-, (8S-cis)- U Naphthalenamine U Naphthalenamine U Naphthalenamine, N,N -bis(2-chloroethyl)- U Naphthalene U Naphthalene, 2-chloro- U ,4-Naphthalenedione U ,7-Naphthalenedisulfonic acid, 3,3 -[(3,3 - dimethyl[1,1 -biphenyl]-4,4 -diyl)bis(azo)bis[5-amino-4-hydroxy]-, tetrasodium salt U Naphthalenol, methylcarbamate. U ,4-Naphthoquinone U alpha-naphthylamine U beta-naphthylamine U Nitric acid, thallium(1+) salt U Nitrobenzene (I,T) U p-nitrophenol U Nitropropane (I,T) U N-Nitrosodi-n-butylamine 68

71 U N-Nitrosodiethanolamine U N-Nitrosodiethylamine U N-Nitroso-N-ethylurea U N-Nitroso-N-methylurea U N-Nitroso-N-methylurethane U N-Nitrosopiperidine U N-Nitrosopyrrolidine U Nitro-o-toluidine U ,2-Oxathiolane, 2,2-dioxide U H-1,3,2-Oxazaphosphorin-2-amine, N,N-bis(2-chloroethyl)tetrahydro-, 2-oxide U Oxirane (I,T) U Oxiranecarboxyaldehyde U Oxirane, (chloromethyl)- U Paraldehyde U Pentachlorobenzene U Pentachloroethane U Pentachloronitrobenzene (PCNB) See F Pentachlorophenol U Pentanol, 4-methyl- U ,3-Pentadiene (I) U Phenacetin U Phenol U Phenol, 2-chloro- U Phenol, 4-chloro-3-methyl- U Phenol, 2,4-dichloro- U Phenol, 2,6-dichloro- U Phenol, 4,4 -(1,2-diethyl-1,2-ethenediyl)bis-, (E)- U Phenol, 2,4-dimethyl- U Phenol, methyl- U Phenol, 2,2 -methylenebis[3,4,6-trichloro- U Phenol, 2-(1-methylethoxy)-, methylcarbamate. U Phenol, 4-nitro- See F Phenol, pentachloro- See F Phenol, 2,3,4,6-tetrachloro- See F Phenol, 2,4,5-trichloro- See F Phenol, 2,4,6-trichloro- U L-Phenylalanine, 4-[bis(2-chloroethyl)amino]- U Phosphoric acid, lead(2+) salt (2:3) U Phosphorodithioic acid, O,O-diethyl S-methyl ester U Phosphorus sulfide (R) U Phthalic anhydride U Picoline 69

72 U Piperidine, 1-nitroso- U Pronamide U Propanamine (I,T) U Propanamine, N-nitroso-N-propyl- U Propanamine, N-propyl- (I) U Propane, 1,2-dibromo-3-chloro- U Propane, 1,2-dichloro- U Propanedinitrile U Propane, 2-nitro- (I,T) U Propane, 2,2 -oxybis[2-chloro- U ,3-Propane sultone See F Propanoic acid, 2-(2,4,5-trichlorophenoxy)- U Propanol, 2,3-dibromo-, phosphate (3:1) U Propanol, 2-methyl- (I,T) U Propanone (I) U Propenamide U Propene, 1,3-dichloro- U Propene, 1,1,2,3,3,3-hexachloro- U Propenenitrile U Propenenitrile, 2-methyl- (I,T) U Propenoic acid (I) U Propenoic acid, ethyl ester (I) U Propenoic acid, 2-methyl-, ethyl ester U Propenoic acid, 2-methyl-, methyl ester (I,T) U Propham. U Propoxur. U Prosulfocarb. U n-propylamine (I,T) U Propylene dichloride U ,6-Pyridazinedione, 1,2-dihydro- U Pyridine U Pyridine, 2-methyl- U ,4-(1H,3H)-Pyrimidinedione, 5-[bis(2- chloroethyl)amino]- U (1H)-Pyrimidinone, 2,3-dihydro-6-methyl-2-thioxo- U Pyrrolidine, 1-nitroso- U Reserpine U Resorcinol U Safrole U Selenious acid U Selenium dioxide U Selenium sulfide U Selenium sulfide SeS 2 (R,T) 70

73 U015 See F027 U206 U103 U189 See F027 U207 U208 U209 U210 See F027 U213 U214 U215 U216 U216 U217 U218 U410 U153 U244 U409 U219 U244 U220 U221 U223 U328 U353 U222 U389 U011 U226 U227 U228 U121 See F027 See F027 U404 U234 U182 U235 U L-Serine, diazoacetate (ester) Silvex (2,4,5-TP) Streptozotocin Sulfuric acid, dimethyl ester Sulfur phosphide (R) ,4,5-T ,2,4,5-Tetrachlorobenzene ,1,1,2-Tetrachloroethane ,1,2,2-Tetrachloroethane Tetrachloroethylene ,3,4,6-Tetrachlorophenol Tetrahydrofuran (I) Thallium(I) acetate Thallium(I) carbonate Thallium(I) chloride thallium chloride TlCl Thallium(I) nitrate Thioacetamide Thiodicarb Thiomethanol (I,T) Thioperoxydicarbonic diamide [(H 2 N)C(S)] 2 S 2, tetramethyl Thiophanate-methyl Thiourea Thiram Toluene Toluenediamine Toluene diisocyanate (R,T) o-toluidine p-toluidine o-toluidine hydrochloride Triallate H-1,2,4-Triazol-3-amine ,1,1-Trichloroethane ,1,2-Trichloroethane Trichloroethylene Trichloromonofluoromethane ,4,5-Trichlorophenol ,4,6-Trichlorophenol Triethylamine ,3,5-Trinitrobenzene (R,T) ,3,5-Trioxane, 2,4,6-trimethyl Tris(2,3-dibromopropyl) phosphate Trypan blue 71

74 U237 U176 U177 U043 U248 U239 U200 U249 U001 U001 U002 U002 U003 U004 U004 U005 U005 U006 U007 U007 U008 U008 U009 U009 U010 U010 U011 U011 U012 U012 U014 U014 U015 U015 U016 U017 U017 U018 U019 U Uracil mustard Urea, N-ethyl-N-nitroso Urea, N-methyl-N-nitroso Vinyl chloride Warfarin, & salts, when present at concentrations of 0.3% or less Xylene (I) Yohimban-16-carboxylic acid, 11,17-dimethoxy-18-[(3,4,5- trimethoxybenzoyl)oxy]-, methyl ester, (3beta,16beta,17alpha,18beta,20alpha) Zinc phosphide Zn 3 P 2, when present at concentrations of 10% or less Acetaldehyde (I) Ethanal (I) Acetone (I) Propanone (I) Acetonitrile (I,T) Acetophenone Ethanone, 1-phenyl Acetamide, -9H-fluoren-2-yl Acetylaminofluorene Acetyl chloride (C,R,T) Acrylamide Propenamide Acrylic acid (I) Propenoic acid (I) Acrylonitrile Propenenitrile Azirino[2',3':3,4]pyrrolo[1,2-a]indole-4,7-dione, 6-amino-8- [[(aminocarbonyl)oxy]methyl]-1,1a,2,8,8a,8b-hexahydro-8a-methoxy-5- methyl-, [1aS-(1aalpha, 8beta,8aalpha,8balpha)] Mitomycin C Amitrole H-1,2,4-Triazol-3-amine Aniline (I,T) Benzenamine (I,T) Auramine Benzenamine, 4,4'-carbonimidoylbis[N,N-dimethyl Azaserine L-Serine, diazoacetate (ester) Benz[c]acridine Benzal chloride Benzene, (dichloromethyl) Benz[a]anthracene Benzene (I,T) Benzenesulfonic acid chloride (C,R) 72

75 U020 U021 U021 U022 U023 U023 U024 U024 U025 U025 U026 U026 U027 U027 U028 U028 U029 U029 U030 U030 U031 U031 U032 U032 U033 U033 U034 U034 U035 U035 U036 U036 U037 U037 U038 U038 U039 U039 U041 U041 U Benzenesulfonyl chloride (C,R) Benzidine [1,1'-Biphenyl]-4,4'-diamine Benzo[a]pyrene Benzene, (trichloromethyl) Benzotrichloride (C,R,T) Dichloromethoxy ethane Ethane, 1,1'-[methylenebis(oxy)]bis[2-chloro Dichloroethyl ether Ethane, 1,1'-oxybis[2-chloro Chlornaphazin Naphthalenamine, N,N'-bis(2-chloroethyl) Dichloroisopropyl ether Propane, 2,2'-oxybis[2-chloro ,2-Benzenedicarboxylic acid, bis(2-ethylhexyl) ester Diethylhexyl phthalate Methane, bromo Methyl bromide Benzene, 1-bromo-4-phenoxy Bromophenyl phenyl ether Butanol (I) n-butyl alcohol (I) Calcium chromate Chromic acid H 2 CrO 4, calcium salt Carbonic difluoride Carbon oxyfluoride (R,T) Acetaldehyde, trichloro Chloral Benzenebutanoic acid, 4-[bis(2-chloroethyl)amino] Chlorambucil Chlordane, alpha & gamma isomers ,7-Methano-1H-indene, 1,2,4,5,6,7,8,8-octachloro-2,3,3a,4,7,7a- hexahydro Benzene, chloro Chlorobenzene Benzeneacetic acid, 4-chloro-alpha-(4-chlorophenyl)-alpha-hydroxy-, ethyl ester Chlorobenzilate p-chloro-m-cresol Phenol, 4-chloro-3-methyl Epichlorohydrin Oxirane, (chloromethyl) Chloroethyl vinyl ether 73

76 U Ethene, (2-chloroethoxy)- U Ethene, chloro- U Vinyl chloride U Chloroform U Methane, trichloro- U Methane, chloro- (I,T) U Methyl chloride (I,T) U Chloromethyl methyl ether U Methane, chloromethoxy- U beta-chloronaphthalene U Naphthalene, 2-chloro- U o-chlorophenol U Phenol, 2-chloro- U Benzenamine, 4-chloro-2-methyl-, hydrochloride U Chloro-o-toluidine, hydrochloride U Chrysene U051 Creosote U Cresol (Cresylic acid) U Phenol, methyl- U Butenal U Crotonaldehyde U Benzene, (1-methylethyl)-(I) U Cumene (I) U Benzene, hexahydro-(i) U Cyclohexane (I) U Cyclohexanone (I) U Cyclophosphamide U H-1,3,2-Oxazaphosphorin-2-amine, N,N-bis(2-chloroethyl)tetrahydro-, 2- oxide U Daunomycin U ,12-Naphthacenedione, 8-acetyl-10-[(3-amino-2,3,6-trideoxy)-alpha-L- lyxo-hexopyranosyl)oxy]-7,8,9,10-tetrahydro-6,8,11-trihydroxy-1-methoxy-, (8S-cis)- U Benzene, 1,1'-(2,2-dichloroethylidene)bis[4-chloro- U DDD U Benzene, 1,1'-(2,2,2-trichloroethylidene)bis[4-chloro- U DDT U Carbamothioic acid, bis(1-methylethyl)-, S-(2,3-di chloro-2-propenyl) ester U Diallate U Dibenz[a,h]anthracene U Benzo[rst]pentaphene U Dibenzo[a,i]pyrene U ,2-Dibromo-3-chloropropane U Propane, 1,2-dibromo-3-chloro- 74

77 U067 U067 U068 U068 U069 U069 U070 U070 U071 U071 U072 U072 U073 U073 U074 U074 U075 U075 U076 U076 U077 U077 U078 U078 U079 U079 U080 U080 U081 U081 U082 U082 U083 U083 U084 U084 U085 U085 U086 U086 U087 U087 U Ethane, 1,2-dibromo Ethylene dibromide Methane, dibromo Methylene bromide ,2-Benzenedicarboxylic acid, dibutyl ester Dibutyl phthalate Benzene, 1,2-dichloro o-dichlorobenzene Benzene, 1,3-dichloro m-dichlorobenzene Benzene, 1,4-dichloro p-dichlorobenzene [1,1'-Biphenyl]-4,4'-diamine, 3,3'-dichloro ,3'-Dichlorobenzidine Butene, 1,4-dichloro-(I,T) ,4-Dichloro-2-butene (I,T) Dichlorodifluoromethane Methane, dichlorodifluoro Ethane, 1,1-dichloro Ethylidene dichloride Ethane, 1,2-dichloro Ethylene dichloride ,1-Dichloroethylene Ethene, 1,1-dichloro ,2-Dichloroethylene Ethene, 1,2-dichloro-, (E) Methane, dichloro Methylene chloride ,4-Dichlorophenol Phenol, 2,4-dichloro ,6-Dichlorophenol Phenol, 2,6-dichloro Propane, 1,2-dichloro Propylene dichloride ,3-Dichloropropene Propene, 1,3-dichloro ,2'-Bioxirane ,2:3,4-Diepoxybutane (I,T) N,N'-Diethylhydrazine Hydrazine, 1,2-diethyl O,O-Diethyl S-methyl dithiophosphate Phosphorodithioic acid, O,O-diethyl S-methyl ester ,2-Benzenedicarboxylic acid, diethyl ester 75

78 U088 U089 U089 U090 U090 U091 U091 U092 U092 U093 U093 U094 U094 U095 U095 U096 U096 U097 U097 U098 U098 U099 U099 U101 U101 U102 U102 U103 U103 U105 U105 U106 U106 U107 U107 U108 U108 U109 U109 U110 U110 U111 U Diethyl phthalate Diethylstilbesterol Phenol, 4,4'-(1,2-diethyl-1,2-ethenediyl)bis-, (E) ,3-Benzodioxole, 5-propyl Dihydrosafrole [1,1'-Biphenyl]-4,4'-diamine, 3,3'-dimethoxy ,3'-Dimethoxybenzidine Dimethylamine (I) Methanamine, -methyl-(i) Benzenamine, N,N-dimethyl-4-(phenylazo) p-dimethylaminoazobenzene Benz[a]anthracene, 7,12-dimethyl ,12-Dimethylbenz[a]anthracene [1,1'-Biphenyl]-4,4'-diamine, 3,3'-dimethyl ,3'-Dimethylbenzidine alpha,alpha-dimethylbenzylhydroperoxide (R) Hydroperoxide, 1-methyl-1-phenylethyl-(R) Carbamic chloride, dimethyl Dimethylcarbamoyl chloride ,1-Dimethylhydrazine Hydrazine, 1,1-dimethyl ,2-Dimethylhydrazine Hydrazine, 1,2-dimethyl ,4-Dimethylphenol Phenol, 2,4-dimethyl ,2-Benzenedicarboxylic acid, dimethyl ester Dimethyl phthalate Dimethyl sulfate Sulfuric acid, dimethyl ester Benzene, 1-methyl-2,4-dinitro ,4-Dinitrotoluene Benzene, 2-methyl-1,3-dinitro ,6-Dinitrotoluene ,2-Benzenedicarboxylic acid, dioctyl ester Di-n-octyl phthalate ,4-Diethyleneoxide ,4-Dioxane ,2-Diphenylhydrazine Hydrazine, 1,2-diphenyl Dipropylamine (I) Propanamine, N-propyl-(I) Di-n-propylnitrosamine Propanamine, N-nitroso-N-propyl- 76

79 U112 U112 U113 U113 U114 U114 U115 U115 U116 U116 U117 U117 U118 U118 U119 U119 U120 U121 U121 U122 U123 U124 U124 U125 U125 U126 U126 U127 U127 U128 U128 U129 U129 U130 U130 U131 U131 U132 U132 U133 U134 U Acetic acid ethyl ester (I) Ethyl acetate (I) Ethyl acrylate (I) Propenoic acid, ethyl ester (I) Carbamodithioic acid, 1,2-ethanediylbis-, salts & esters Ethylenebisdithiocarbamic acid, salts & esters Ethylene oxide (I,T) Oxirane (I,T) Ethylenethiourea Imidazolidinethione Ethane, 1,1'-oxybis-(I) Ethyl ether (I) Ethyl methacrylate Propenoic acid, 2-methyl-, ethyl ester Ethyl methanesulfonate Methanesulfonic acid, ethyl ester Fluoranthene Methane, trichlorofluoro Trichloromonofluoromethane Formaldehyde Formic acid (C,T) Furan (I) Furfuran (I) Furancarboxaldehyde (I) Furfural (I) Glycidylaldehyde Oxiranecarboxyaldehyde Benzene, hexachloro Hexachlorobenzene ,3-Butadiene, 1,1,2,3,4,4-hexachloro Hexachlorobutadiene Cyclohexane, 1,2,3,4,5,6-hexachloro-, (1alpha,2alpha,3beta,4alpha,5alpha,6beta) Lindane ,3-Cyclopentadiene, 1,2,3,4,5,5-hexachloro Hexachlorocyclopentadiene Ethane, hexachloro Hexachloroethane Hexachlorophene Phenol, 2,2'-methylenebis[3,4,6-trichloro Hydrazine (R,T) Hydrofluoric acid (C,T) Hydrogen fluoride (C,T) 77

80 U Hydrogen sulfide U Hydrogen sulfide H 2 S U Arsinic acid, dimethyl- U Cacodylic acid U Indeno[1,2,3-cd]pyrene U Methane, iodo- U Methyl iodide U Isobutyl alcohol (I,T) U Propanol, 2-methyl- (I,T) U ,3-Benzodioxole, 5-(1-propenyl)- U Isosafrole U Kepone U ,3,4-Metheno-2H-cyclobuta[cd]pentalen-2-one, 1,1a,3,3a,4,5,5,5a,5b,6- decachlorooctahydro- U Butenoic acid, 2-methyl-, 7-[[2,3-dihydroxy-2-(1-methoxyethyl)-3- methyl-1-oxobutoxy]methyl]-2,3,5,7a-tetrahydro-1h-pyrrolizin-1-yl ester, [1S-[1alpha(Z),7(2S*,3R*),7aalpha]]- U Lasiocarpine U Acetic acid, lead(2+) salt U Lead acetate U Lead phosphate U Phosphoric acid, lead(2+) salt (2:3) U Lead, bis(acetato-o)tetrahydroxytri- U Lead subacetate U ,5-Furandione U Maleic anhydride U Maleic hydrazide U ,6-Pyridazinedione, 1,2-dihydro- U Malononitrile U Propanedinitrile U Melphalan U L-Phenylalanine, 4-[bis(2-chloroethyl)amino]- U Mercury U Methacrylonitrile (I,T) U Propenenitrile, 2-methyl- (I,T) U Methanethiol (I,T) U Thiomethanol (I,T) U Methanol (I) U Methyl alcohol (I) U ,2-Ethanediamine, N,N-dimethyl-N'-2-pyridinyl-N'-(2-thienylmethyl)- U Methapyrilene U Carbonochloridic acid, methyl ester (I,T) U Methyl chlorocarbonate (I,T) U Benz[j]aceanthrylene, 1,2-dihydro-3-methyl- 78

81 U157 U158 U158 U159 U159 U160 U160 U161 U161 U161 U162 U162 U163 U163 U164 U164 U165 U166 U166 U167 U167 U168 U168 U169 U169 U170 U170 U171 U171 U172 U172 U173 U173 U174 U174 U176 U176 U177 U177 U178 U178 U179 U Methylcholanthrene Benzenamine, 4,4'-methylenebis[2-chloro ,4'-Methylenebis(2-chloroaniline) Butanone (I,T) Methyl ethyl ketone (MEK) (I,T) Butanone, peroxide (R,T) Methyl ethyl ketone peroxide (R,T) Methyl isobutyl ketone (I) Methyl-2-pentanone (I) Pentanol, 4-methyl Methyl methacrylate (I,T) Propenoic acid, 2-methyl-, methyl ester (I,T) Guanidine, -methyl-n'-nitro-n-nitroso MNNG Methylthiouracil (1H)-Pyrimidinone, 2,3-dihydro-6-methyl-2-thioxo Naphthalene ,4-Naphthalenedione ,4-Naphthoquinone Naphthalenamine alpha-naphthylamine Naphthalenamine beta-naphthylamine Benzene, nitro Nitrobenzene (I,T) p-nitrophenol Phenol, 4-nitro Nitropropane (I,T) Propane, 2-nitro- (I,T) Butanamine, N-butyl-N-nitroso N-Nitrosodi-n-butylamine Ethanol, 2,2'-(nitrosoimino)bis N-Nitrosodiethanolamine Ethanamine, -ethyl-n-nitroso N-Nitrosodiethylamine N-Nitroso-N-ethylurea Urea, N-ethyl-N-nitroso N-Nitroso-N-methylurea Urea, N-methyl-N-nitroso Carbamic acid, methylnitroso-, ethyl ester N-Nitroso-N-methylurethane N-Nitrosopiperidine Piperidine, 1-nitroso- 79

82 U180 U180 U181 U181 U182 U182 U183 U183 U184 U184 U185 U185 U186 U186 U187 U187 U188 U189 U189 U190 U190 U191 U191 U192 U192 U193 U193 U194 U194 U196 U197 U197 U200 U200 U201 U201 U203 U203 U204 U204 U N-Nitrosopyrrolidine Pyrrolidine, 1-nitroso Benzenamine, 2-methyl-5-nitro Nitro-o-toluidine ,3,5-Trioxane, 2,4,6-trimethyl Paraldehyde Benzene, pentachloro Pentachlorobenzene Ethane, pentachloro Pentachloroethane Benzene, pentachloronitro Pentachloronitrobenzene (PCNB) Methylbutadiene (I) ,3-Pentadiene (I) Acetamide, -(4-ethoxyphenyl) Phenacetin Phenol Phosphorus sulfide (R) Sulfur phosphide (R) ,3-Isobenzofurandione Phthalic anhydride Picoline Pyridine, 2-methyl Benzamide, 3,5-dichloro-N-(1,1-dimethyl-2-propynyl) Pronamide ,2-Oxathiolane, 2,2-dioxide ,3-Propane sultone Propanamine (I,T) n-propylamine (I,T) Pyridine p-benzoquinone ,5-Cyclohexadiene-1,4-dione Reserpine Yohimban-16-carboxylic acid, 11,17-dimethoxy-18-[(3,4,5- trimethoxybenzoyl)oxy]-, methyl ester,(3beta,16beta,17alpha,18beta,20alpha) ,3-Benzenediol Resorcinol ,3-Benzodioxole, 5-(2-propenyl) Safrole Selenious acid Selenium dioxide Selenium sulfide 80

83 U Selenium sulfide SeS 2 (R,T) U Glucopyranose, 2-deoxy-2-(3-methyl-3-nitrosoureido)-, D- U D-Glucose, 2-deoxy-2-[[(methylnitrosoamino)-carbonyl]amino]- U Streptozotocin U Benzene, 1,2,4,5-tetrachloro- U ,2,4,5-Tetrachlorobenzene U Ethane, 1,1,1,2-tetrachloro- U ,1,1,2-Tetrachloroethane U Ethane, 1,1,2,2-tetrachloro- U ,1,2,2-Tetrachloroethane U Ethene, tetrachloro- U Tetrachloroethylene U Carbon tetrachloride U Methane, tetrachloro- U Furan, tetrahydro-(i) U Tetrahydrofuran (I) U Acetic acid, thallium(1+) salt U Thallium(I) acetate U Carbonic acid, dithallium(1+) salt U Thallium(I) carbonate U Thallium(I) chloride U Thallium chloride TlCl U Nitric acid, thallium(1+) salt U Thallium(I) nitrate U Ethanethioamide U Thioacetamide U Thiourea U Benzene, methyl- U Toluene U Benzenediamine, ar-methyl- U Toluenediamine U Benzenamine, 2-methyl-, hydrochloride U o-toluidine hydrochloride U Benzene, 1,3-diisocyanatomethyl- (R,T) U Toluene diisocyanate (R,T) U Bromoform U Methane, tribromo- U Ethane, 1,1,1-trichloro- U Methyl chloroform U ,1,1-Trichloroethane U Ethane, 1,1,2-trichloro- U ,1,2-Trichloroethane U Ethene, trichloro- 81

84 U Trichloroethylene U Benzene, 1,3,5-trinitro- U ,3,5-Trinitrobenzene (R,T) U Propanol, 2,3-dibromo-, phosphate (3:1) U Tris(2,3-dibromopropyl) phosphate U ,7-Naphthalenedisulfonic acid, 3,3'-[(3,3'-dimethyl[1,1'-biphenyl]-4,4'- diyl)bis(azo)bis[5-amino-4-hydroxy]-, tetrasodium salt U Trypan blue U ,4-(1H,3H)-Pyrimidinedione, 5-[bis(2-chloroethyl)amino]- U Uracil mustard U Carbamic acid, ethyl ester U Ethyl carbamate (urethane) U Benzene, dimethyl- (I,T) U Xylene (I) U Acetic acid, (2,4-dichlorophenoxy)-, salts & esters U ,4-D, salts & esters U Hexachloropropene U Propene, 1,1,2,3,3,3-hexachloro- U Thioperoxydicarbonic diamide [(H 2 N)C(S)] 2 S 2, tetramethyl- U Thiram U Cyanogen bromide (CN)Br U Benzene, 1,1'-(2,2,2-trichloroethylidene)bis[4- methoxy- U Methoxychlor U H-1-Benzopyran-2-one, 4-hydroxy-3-(3-oxo-1-phenyl-butyl)-, & salts, when present at concentrations of 0.3% or less U Warfarin, & salts, when present at concentrations of 0.3% or less U Zinc phosphide Zn 3 P 2, when present at concentrations of 10% or less U Benomyl U Carbamic acid, [1-[(butylamino)carbonyl]-1H-benzimidazol-2-yl]-, methyl ester U Bendiocarb U ,3-Benzodioxol-4-ol, 2,2-dimethyl-, methyl carbamate U Carbaryl U Naphthalenol, methylcarbamate U Barban U Carbamic acid, (3-chlorophenyl)-, 4-chloro-2-butynyl ester U Benzenamine, 2-methyl- U o-toluidine U Benzenamine, 4-methyl- U p-toluidine U Ethanol, 2-ethoxy- U Ethylene glycol monoethyl ether U Bendiocarb phenol U ,3-Benzodioxol-4-ol, 2,2-dimethyl-, 82

85 U367 U367 U372 U372 U373 U373 U387 U387 U389 U389 U394 U394 U395 U395 U404 U404 U409 U409 U410 U410 U411 U411 See F027 See F027 See F027 See F027 See F027 See F027 See F027 See F027 See F027 See F027 See F027 See F Benzofuranol, 2,3-dihydro-2,2-dimethyl Carbofuran phenol Carbamic acid, 1H-benzimidazol-2-yl, methyl ester Carbendazim Carbamic acid, phenyl-, 1-methylethyl ester Propham Carbamothioic acid, dipropyl-, S-(phenylmethyl) ester Prosulfocarb Carbamothioic acid, bis(1-methylethyl)-, S-(2,3,3-trichloro-2-propenyl) ester Triallate A Ethanimidothioic acid, 2-(dimethylamino)-N-hydroxy-2-oxo-, methyl ester Diethylene glycol, dicarbamate Ethanol, 2,2'-oxybis-, dicarbamate Ethanamine, N,N-diethyl Triethylamine Carbamic acid, [1,2-phenylenebis (iminocarbonothioyl)]bis-, dimethyl ester Thiophanate-methyl Ethanimidothioic acid, N,N'-[thiobis[(methylimino)carbonyloxy]]bis-, dimethyl ester Thiodicarb Phenol, 2-(1-methylethoxy)-, methylcarbamate Propoxur Acetic acid, (2,4,5-trichlorophenoxy) Pentachlorophenol Phenol, pentachloro Phenol, 2,3,4,6-tetrachloro Phenol, 2,4,5-trichloro Phenol, 2,4,6-trichloro Propanoic acid, 2-(2,4,5-trichlorophenoxy) Silvex (2,4,5-TP) ,4,5-T ,3,4,6-Tetrachlorophenol ,4,5-Trichlorophenol ,4,6-Trichlorophenol 1 CAS Number given for parent compound only. [Comment: For the convenience of the regulated community, the primary hazardous properties of these materials have been indicated by the letters T (Toxicity), R (Reactivity), I (Ignitability) and C (Corrosivity). Absence of a letter indicates that the compound is only listed for toxicity. Wastes are first listed in alphabetical order by substance and then listed [45 FR 78529, 78541, Nov. 25, 1980] 83

86 TRAINING / COMPLIANCE MANUAL FOR COMPLIANCE WITH THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) / HAZARDOUS WASTE REGULATIONS Company Name Street Address City State Zip Mailing Address Mailing Address City Mailing Address State Mailing Address Zip Contact Person (Environmental Information) EPA Identification Number Completed on (date) Revised on (date) The information contained in this handbook is an overview of the hazardous waste management program in Kansas. The state and federal regulations should be consulted for more detailed information. Electronic copies of the federal and state regulations may be found at the following websites: Federal Regulations: Kansas Regulations at the KDHE website: The KDHE website also has policies, technical guidance documents, and other compliance tools available. This document was last revised by KDHE on April 16, 2014.

87 1.0 INTRODUCTION This manual is designed to help Conditionally Exempt Small Quantity Generators (CESQGs), Kansas Small Quantity Generators (KSQGs) and Small Quantity Generators (SQGs) of hazardous waste remain in compliance with the state and federal hazardous waste regulations. When completed, this manual can be used as a guide to train employees on the specific types of hazardous waste generated at a facility and on the specific requirements to which that facility is subject. A representative of the facility should first fill in all the blanks in this document to make it specific to their facility. This will include completing Attachments B, C, and D as described in the following sections. This will enable the facility to determine their hazardous waste generator classification (CESQG, KSQG, SQG, or Large Quantity Generator (LQG)). It will also identify the areas of the facility where hazardous waste is being generated and managed and who at the facility is responsible for the management of that waste. The employees that are responsible for the management of hazardous waste (i.e., labeling, dating, closing, inspecting, moving, etc.) should all be trained so that they are familiar with proper waste handling and emergency procedures relevant to their specific job duties. In general, employees responsible for managing hazardous waste should be trained in the following areas, depending on an employee s duties (Attachment A provides a checklist that can be used to document training): Hazardous Waste Generator Classifications (CESQG, KSQG, SQG, LQG) KDHE notification of hazardous waste activity Identification of hazardous waste (hazardous waste determination) Emergency response (fire, spills, etc.) Ensure that emergency preparedness requirements are met (Arrangements are made with local emergency response agencies including fire, police, and hospitals) Recordkeeping Container management Labeling containers Hazardous Waste Properly closing hazardous waste containers Marking storage containers with the accumulation start date Inspecting hazardous waste storage areas to ensure that containers are in good condition, properly labeled and closed, have proper aisle space and that incompatible wastes are not stored together. Properly documenting hazardous waste storage area inspections Ensuring that satellite accumulation containers are properly managed - 2 -

88 2.0 BRIEF HISTORY OF HAZARDOUS WASTE REGULATION The Resource Conservation & Recovery Act (RCRA) was passed in As a result of this act, the U.S. Environmental Protection Agency (EPA) was tasked to create and implement regulations for the management of hazardous waste. RCRA regulates hazardous waste from the point inside a facility where it is generated to its final disposal location (cradle to grave). Kansas is authorized by EPA to regulate the management of hazardous waste generated, transported, treated, and/or disposed in Kansas. Kansas made significant revisions to the regulations in HAZARDOUS WASTE MANAGEMENT IN KANSAS Kansas regulates hazardous waste at a lower quantity than EPA, which means that Kansas has more stringent requirements. In Kansas there are currently four generator classifications: Conditionally Exempt Small Quantity Generator (CESQG) Generates less than 55 pounds of hazardous waste in a single month. Never accumulates 2,200 pounds or more of hazardous waste. Accumulating 2,200 pounds or more would cause the generator to be regulated as a SQG. Generates less than 2.2 pounds of acutely hazardous waste in a single month. Never accumulates 2.2 pounds or more of acutely hazardous waste. Accumulating 2.2 pounds or more of acutely hazardous waste would cause the generator to be regulated as a LQG. Kansas Small Quantity Generator (KSQG) Generates 55 pounds or more, but no more than 220 pounds of hazardous waste in a single month. Never accumulates 2,200 pounds or more of hazardous waste. Accumulating 2,200 or more pounds would cause the generator to be regulated as a SQG. Generates less than 2.2 pounds of acutely hazardous waste in a single month. Never accumulates 2.2 pounds or more of acutely hazardous waste. Accumulating 2.2 pounds or more of acutely hazardous waste would cause the generator to be regulated as a LQG. Small Quantity Generator (SQG) Generates more than 220 pounds or more, but less than 2,200 pounds of hazardous waste in a single month. Never accumulates more than 13,200 pounds of hazardous waste. Accumulating more than 13,200 pounds would cause the generator to be regulated as a treatment, storage, and/or disposal facility (TSDF). Generates less than 2.2 pounds of acutely hazardous waste in a single month. Never accumulates 2.2 pounds or more of acutely hazardous waste. Accumulating 2.2 pounds or more of acutely hazardous waste would cause the generator to be regulated as a LQG. Accumulates waste on-site for less than 180 days, or 270 days if shipping waste more than 200 miles

89 LQG Generator (LQG) Generates 2,200 pounds or more of hazardous waste in a single month. Generates 2.2 pounds or more of acutely hazardous waste in a single month. Accumulates 2.2 pounds or more of acutely hazardous waste. Accumulates waste on-site for less than 90 days. RCRA puts the responsibility for proper management of hazardous waste on the generator. It is the generator s responsibility to ensure that the waste is properly managed from the point of generation to final disposal. A generator cannot release itself from liability for the waste simply by hiring a contractor. It is therefore imperative that each generator understand the responsibilities associated with generating hazardous waste. This manual is a guide to help ensure that hazardous waste is properly managed at the facility at all times. 4.0 STEPS TOWARDS COMPLIANCE The following steps should be followed to properly manage hazardous waste: Step 1 This step will help identify all of the waste streams generated at the facility, and determine which ones are hazardous. Start by completing the Industrial Waste Inventory Form included in Attachment B for each waste stream. Technical Guidance Document (TGD) HW-2011-G1: Hazardous Waste Determinations and Documentation is also available on the KDHE website and provides more information on conducting a hazardous waste determination. This TGD also includes a form that would also work for documenting the hazardous waste determination for each waste stream. Step 2 Add up the number of pounds of hazardous waste generated per month (Questions 4 and 5 in Attachment B). Please note that averages cannot be used; the maximum monthly generation rate should be used. Step 3 Determine your generator status by comparing the total amount of hazardous waste generated per month to the generator classifications listed in Section 3.0. Step 4 Review the regulatory requirements for each generator classification as described in the following sections of the manual. CESQG Requirements Section 5.1 KSQG Requirements Section 5.2 SQG Requirements Section 5.3 LQG Requirements Section 5.4 Step 5 Ensure that the facility is in compliance with the regulatory requirements for its generator classification. Step 6 Review this completed manual each year with applicable employees to ensure that training requirements are met for KSQGs and SQGs. Don t forget to document the training using the form found in Attachment A, Hazardous Waste Management Training Documentation. Note that not all topics are applicable for all employees. Employees only need to be trained on their individual hazardous waste management duties

90 5.0 GENERATOR REQUIREMENTS Electronic copies of the Kansas hazardous waste regulations can be found in the Kansas Administrative Regulations (K.A.R.) and may be downloaded from the KDHE Bureau of Waste Management website. The address for this website can be found on the front of this document. 5.1 Conditionally Exempt Small Quantity Generator (CESQG) Requirements CESQGs must make a hazardous waste determination on each waste stream generated at their facility. KDHE has a technical guidance document to assist you in making and documenting your hazardous waste determination. The technical guidance document can be found at the web address found on the cover of this document. All CESQGs must ensure that their waste is properly disposed or recycled. If a CESQG accumulates less than 55 pounds of hazardous waste on-site, then they may dispose of their waste through one of the following options: A household hazardous waste (HHW) facility that is permitted by the secretary of KDHE and follows all associated regulations and policies. Through a hazardous waste contractor taking the waste to a permitted hazardous waste treatment, storage, or disposal facility. A municipal solid waste landfill (liquids must be solidified before disposal). If a CESQG accumulates 55 pounds or more (NOT GALLONS) of hazardous waste on-site, then they must ensure that the waste is managed as follows: Each container is labeled Hazardous Waste. Each container has an accumulation start date marked on it. Each container is in good condition. Each container is compatible with the contents of the container. Each container is closed except when adding or removing waste. Monthly inspections are conducted and documented as follows: Date of the inspection; Time of the inspection; Name of the inspector; Notation of the observations made; Date and nature of any repairs or other remedial actions. The monthly inspection logs must be kept for a minimum of 3 years. An example of an inspection log can be found in Attachment E. Each CESQG accumulating 55 pounds or more of hazardous waste on-site at any time must use one of the following disposal options: Disposal at an HHW facility that is permitted by the secretary of KDHE and follows all associated regulations and policies

91 All applicable DOT requirements must be followed. Contact the Federal Motor Carrier Safety Administration (FMCSA) at (785) for questions about DOT requirements. Disposal at a permitted treatment, storage, or disposal facility (TSDF). The hazardous waste must be transported by a transporter that has an EPA ID number and is registered with KDHE. A Uniform Hazardous Waste Manifest must be used. All applicable DOT requirements must be followed. 5.2 Kansas Small Quantity Generator (KSQG) Requirements Each KSQG is subject to all of the following requirements EPA Identification Number Each KSQG shall notify the Kansas Department of Health and Environment (KDHE) of their hazardous waste activity and obtain an EPA Identification Number from KDHE. This is a 12- digit number assigned to the physical location of that facility. The notification is done using a form available on the following KDHE Bureau of Waste Management (BWM) website (the address for the website can be found on the cover of this document). If the information on the form changes, the facility must submit an updated form to KDHE BWM within 60 days of the change(s). The EPA Identification Number stays with that physical location, even if the facility moves to a new address. If the facility moves to a new address, the facility is required to submit a new notification form to KDHE and obtain a new number Waste Determination All KSQGs must make a hazardous waste determination on each industrial waste stream generated at their facility. The results of that waste determination must be kept for 3 years from the time the last shipment of that waste was shipped off-site. KDHE has a technical guidance document to assist you in making and documenting your hazardous waste determination. The technical guidance document can be found at the web address found on the cover of this document Training Each employee of a KSQG is required to be thoroughly familiar with proper waste handling and emergency procedures that are relevant to their job responsibilities during normal facility operations and emergencies. Attachment A contains an example of a form that can be used to document training that each employee has received. Not all topics will be relevant for all employees. An employee only needs to be trained on their individual hazardous waste management duties. Employees must be trained within 6 months of hire or transferring to a new position, and they must receive annual training after that

92 5.2.4 Emergency Coordinator and Response The following emergency information must be posted next to at least one telephone that is accessible, with little or no delay, by employees during an emergency: Name and telephone number of the emergency coordinator; Location of fire extinguishers and spill-control material, and if present, fire alarms; and Telephone number of the fire department (911 is acceptable) unless the facility has a direct alarm. An example of a form that can be used can be found in Attachment C. The emergency coordinator or designee must be prepared to respond to any emergency that arises as follows: In the event of a fire, the emergency coordinator or designee shall call the fire department or attempt to extinguish the fire using a fire extinguisher. In the event of a spill, the emergency coordinator or designee shall contain the flow of hazardous waste to the extent possible and, as soon as practicable, clean up the hazardous waste and any contaminated materials or soil. In the event of a fire, explosion, or other release that could threaten human health outside the facility, or when it appears that a spill has reached surface water, the emergency coordinator shall immediately notify the national response center using the 24-hour tollfree number , and shall include the following information: Name, address and U.S. EPA ID Number (front of this document); Quantity and type of hazardous waste involved in the incident; Extent of any injuries; Estimated quantity and disposition of recovered materials, if any Recordkeeping The following records must be kept by each KSQG and must be available for review during an inspection: Waste determination documentation must be kept for three years from the date of the last shipment of that waste. Signed copy of the hazardous waste manifests must be kept for three years. Copy of each manifest exception report must be kept for three years. Inspection Logs must be kept for three years. Training documentation must be kept for three years Container Management Any container holding hazardous waste must meet the following requirements: Labeled with the words Hazardous Waste Closed except when adding or removing waste Good condition (no severe dents, rusting, holes, etc.) Compatible with the waste it is holding

93 Additional requirements must be met depending if the container is a satellite accumulation container or a storage container. It is recommended that an inventory be kept of all locations where hazardous waste is accumulated, including both satellite and storage locations. An example inventory form, along with a blank form, can be found in Attachment D Satellite Accumulation Container If a container meets all of the following criteria, it can be managed as a satellite accumulation container: One container (not multiple containers) of each type of hazardous waste up to 55 gallons. Located at or near the point of generation. Under the control of the operator of the process generating the waste. Satellite containers must be managed as described in section 5.2.6, and must additionally have the accumulation start date marked on them as soon as the container becomes full or no longer meets the definition of a satellite container. A container would stop meeting the definition of a satellite in the following two examples: 1. If the process generating the waste shuts down; and 2. A second container is added at that location for the same waste stream. Once a container becomes full, or otherwise no longer meets the definition of satellite, it must be moved to the hazardous waste storage area within three calendar days, or must be managed as a storage container at its present location within three calendar days Storage Container Each hazardous waste storage container must be managed as described in section 5.2.6, and must additionally be managed as follows: Marked with the accumulation start date. A dike, berm, wall, or other means separates containers of waste incompatible with other containers stored nearby. Conduct and document monthly inspections. Monthly inspections of the hazardous waste storage area must be documented in a log or summary that includes all of the following: Date of the inspection. Time of the inspection. Name of the inspector. Notation of the observations made. Date and nature of any repairs or other remedial actions. An example of an inspection log can be found in Attachment E. There is no storage time limit for a CESQGs and KSQGs. However, neither a CESQG nor a KSQG can accumulate 2,200 pounds or more of hazardous waste on-site. If 2,200 pounds or more of hazardous waste is accumulated on-site, they become a SQG

94 5.2.7 Emergency Preparedness and Prevention Requirements KSQGs must maintain adequate aisle space to allow unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operations in an emergency (unless aisle space is not needed for any of these purposes). When hazardous waste is being handled, KSQGs must provide personnel with immediate access to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee (unless such a device is not required based on the types of wastes generated). As appropriate, KSQGs must make arrangements with local emergency response agencies to respond to specific hazardous waste emergencies at their facility. These agencies include police, fire, and hospitals. Each agency must be made aware of the types of hazardous waste managed at the facility Waste Disposal Options Each KSQG must use one of the following disposal options: Disposal at an HHW facility that is permitted by the secretary of KDHE and follows all associated regulations and policies. All applicable DOT requirements must be followed. Contact the Federal Motor Carrier Safety Administration (FMCSA) at (785) for questions about DOT requirements. Disposal at a permitted treatment, storage, or disposal facility (TSDF). The hazardous waste must be transported by a transporter that has an EPA ID number and is registered with KDHE. A Uniform Hazardous Waste Manifest must be used. All applicable DOT requirements must be followed. 5.3 Small Quantity Generator (SQG) Requirements Each SQG is subject to all of the KSQG requirements found in Sections through 5.2.7, with the following exception. SQGs must meet all storage container requirements found in Section , but must conduct weekly inspections instead of monthly. Additionally, SQGs must not store hazardous waste on-site for more than 180 days, or 270 days if they are shipping their waste over 200 miles (accumulation time limit). Exceeding the 180-day time limit or the on-site accumulation limit of less than 13,200 pounds (previously mentioned in Section 3.0) at any time will cause the SQG to become subject to permitting requirements of a TSDF. SQGs must dispose of their hazardous waste at a permitted TSDF as follows: The hazardous waste must be transported by a transporter that has an EPA ID number and is registered with KDHE. A Uniform Hazardous Waste Manifest must be used

95 A Land Disposal Restriction (LDR) form must be included with the initial shipment of each waste to each TSDF. All applicable DOT requirements must be followed. 5.4 Large Quantity Generator (LQG) Requirements Each LQG is subject to all of the KSQG requirements found in Sections through 5.2.7, with the following exception. LQGs must meet all storage container requirements found in Section , but must conduct weekly inspections instead of monthly. Additional requirements for training, emergency preparedness, and storage time limits also apply to LQG generators. In brief, these requirements include extensive training for employees, a written contingency plan, and a 90-day time limit for storage of hazardous waste (from the accumulation start date). More detailed information may be found in the Kansas Administrative Regulations. This manual is not designed to fulfill the requirements of a LQG

96 ATTACHMENT A HAZARDOUS WASTE MANAGEMENT TRAINING DOCUMENTATION Employee Name: Employee Title/Position: Waste or area for which employee responsible: Description of Training Date Initials Hazardous Waste Generator Classifications KDHE notification of hazardous waste activity Identification of hazardous waste (hazardous waste determination) Emergency response (fire, spills, etc.) Ensure that emergency preparedness requirements are met (Arrangements are made with local emergency response agencies including fire, police, and hospitals) Recordkeeping Container management Labeling containers Hazardous Waste Properly closing hazardous waste containers Marking storage containers with the accumulation start date Inspecting hazardous waste storage areas to ensure that containers are in good condition, properly labeled and closed, have proper aisle space and that incompatible wastes are not stored together. Properly documenting hazardous waste storage area inspections Ensuring that satellite accumulation containers are properly managed

97 ATTACHMENT B INDUSTRIAL WASTE INVENTORY FORM 1. Waste stream name Name or description of the process generating the waste List each point of generation for this waste (each place where this waste is generated) How many pounds of this waste are generated per month? Is this a hazardous waste or a non-hazardous waste? How was the determination made? [Attach all supporting MSDS sheets and analytical data.] If this is a non-hazardous waste, stop here. 7. If this waste is hazardous, list the waste codes List the location of all satellite accumulation containers for this waste. List the person responsible for managing each satellite location. 10. List all storage locations for this waste List the person responsible for managing each storage location. Who conducts the weekly or monthly inspections of each storage location? 13. Who transports this waste from the site? Where is the final treatment/disposal location for this waste? List all other applicable information about this waste

98 ATTACHMENT C HAZARDOUS WASTE EMERGENCY RESPONSE EMERGENCY COORDINATOR: HOME PHONE NUMBER: CELL PHONE NUMBER (Optional): ALTERNATE EMERGENCY COORDINATOR: HOME PHONE NUMBER: CELL PHONE NUMBER (Optional): FIRE DEPARTMENT PHONE NUMBER: (unless there is a direct alarm) εεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεε EQUIPMENT LOCATION (A map showing the locations is sufficient) FIRE EXTINGUISHERS: SPILL CONTROL: FIRE ALARMS (if present): εεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεεε RESPONSE ACTION FIRE: Call the Fire Department or extinguish the fire using an appropriate fire extinguisher. SPILL: Contain the flow of hazardous waste. Clean up the hazardous waste and any contaminated materials or soil as soon as possible. FIRE, EXPLOSION, OR RELEASE, WHICH THREATENS HUMAN HEALTH OR SURFACE WATER: Notify the National Response Center with the following information: $ Name, address, and U.S. EPA ID Number of generator $ Date, time, and type of incident $ Quantity and type of hazardous waste involved $ Extent of any injuries $ Estimated quantity and disposition of recovered materials NATIONAL RESPONSE CENTER KANSAS DEPARTMENT OF HEALTH AND ENVIRONMENT (785)

99 ATTACHMENT D INVENTORY OF ACCUMULATION LOCATIONS EXAMPLE TABLE Name of Location Area Where Located Type of Accumulation Waste Accumulated Person Responsible Parts Washer Machine Satellite Mineral Spirits John Smith Shop ( ) Paint Filters Paint Booth Satellite Paint Filters Jane Doe ( ) HW Storage Area Storage Shed Storage All Hazardous John Smith Waste ( ) Description of Container Red, 5-gallon, metal Blue, 55-gallon metal All types Comments Used for Paint Booths 1 and 2 Contact John Smith to move waste to storage

100 ATTACHMENT D INVENTORY OF ACCUMULATION LOCATIONS Complete the following table. Name of Location Area Where Located Type of Accumulation Waste Accumulated Person Responsible Description of Container Comments

101 ATTACHMENT E WEEKLY INSPECTIONS OF HAZARDOUS WASTE STORAGE CONTAINERS (MONTHLY INSPECTIONS FOR CESQG AND KSQG) Condition of Containers Condition of Storage Area Inspection Segregation Marked Adequate Accum. Closed/ Good of Corrective Actions Hazardous Aisle Date Time Start Date sealed Condition Incompatible Taken Waste Space Waste Date of Corrective Actions Name of the Inspector (no initials) Yes Acceptable No Denotes a problem KEEP ON FILE FOR A MINIMUM OF THREE YEARS